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Polskie Gornictwo Naftowe i Gazownictwo SA - Polish Oil and Gas Company

PGNiG SA

PGNiG is Poland's leading natural gas company, active in exploration, production, trade, storage and distribution across Poland and international markets.

Lobbying Activity

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.

PGNiG Urges Inclusion of Biomass in Fast-Track Energy Zones

27 Jul 2022
Topic — EU guidance on accelerating permitting for renewable energy and power purchase agreements.
Message — PGNiG requests including biomass combustion units in "renewables go-to areas." They propose removing specific exclusions from the renewable energy directive. This would grant biomass projects shorter permitting deadlines.12
Why — This change would reduce administrative burdens and accelerate biomass power plant development.3
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Response to Review of the de minimis aid Regulation

25 Jul 2022

GENERAL COMMENTS • Revision of the threshold of the de minimis aid is essential for companies affected by current economic situation, e.g. inflation, among others. • Taking into account the above-mentioned as well as post-covid recovery phase, it is reasonable to increase the de minimis aid threshold from 200.000 EUR to 800.000 EUR to enable bigger financial support for companies. • Considering that the threshold for capital groups is determined for whole groups, financial support for subsidiaries may be insufficient. Therefore, mechanism to count de minimis aid for each company within a capital group separately should be considered. • Proposal for mandatory register may be very profitable for beneficiaries, as it can reduce the administrative burden of monitoring de minimis aid. However, to guarantee that mandatory register will fulfill its role, adequate tools ensuring that each case of aid will be included in the register, should be provided.
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Response to Regulation on REPowerEU chapters

18 Jul 2022

PGNiG POSITION ON THE REVISION OF THE REGULATION (EU) 2021/241 AS REGARDS REPOWEREU CHAPTERS IN RECOVERY AND RESILIENCE PLANS (2022/0164 (COD)) PGNiG welcomes REPowerEU’s objectives to boost gas supply diversification, accelerate the completion of gas infrastructure and hydrogen (H2) deployment. PGNiG is in favor of the proposal to include additional chapters in the Resilience and Recovery Plans (RRPs) related to delivering the REPowerEU objectives, however, we would like to address the following comments. PGNiG agrees that RRPs submitted by Member States should help reach the objective of improving energy infrastructure and facilities to meet immediate security of supply needs for oil and gas [Article 21c 1 (b)] and of increasing production and uptake of sustainable biomethane [Article 21c 1 (c)]. However, we cannot concur that the RepowerEU chapters in the RRPs only refer to renewable and ‘fossil-free H2’. We recommend that the Commission takes an inclusive and technology-neutral approach allowing all forms of H2, including low-carbon H2 produced with natural gas using carbon capture and storage (CCS), to compete with other low-carbon emission technologies.Technology neutrality should be the main approach as it will ensure full hydrogen’s potential for reaching climate neutral economy. Technology-neutral approach drives the most cost-efficient and cost-effective emissions reduction and at the current stage of development regarding specific hydrogen technologies, the success or failure of particular technology should not be predetermined. Excluding low carbon H2 produced from natural gas and CCS from the proposed RRPs REPowerEU chapters would send a wrong signal to companies which are currently developing H2 projects and can pre-empt the EU to reach decarbonization objectives at low cost for society. While the current level of natural gas prices may lead to consider low carbon H2 becoming less competitive versus green H2, it is important to remember that the European gas market will rebalance over the coming years with supplies coming from other sources. Furthermore, the cost to produce green H2 increased in parallel with the cost to produce low-carbon (blue) H2, and therefore the relative competitiveness of low-carbon (blue) H2 versus green H2 has not changed. The natural gas market in Europe will rebalance Russian supplies in the next years and low-carbon hydogen will play a key role to enable the EU to reach climate neutrality by 2050 at competitive prices. In this context is important that the policy framework is technology-neutral to allow a fair competition of all low-carbon technologies.
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PGNiG warns EU industrial emission rules threaten energy security

23 Jun 2022
Topic — The European Union is updating rules to lower pollution from large industrial plants.
Message — PGNiG calls for energy security exemptions and extending upgrade deadlines to eight years. They also want tighter restrictions on public legal challenges against permits.123
Why — This would protect the company from high compliance costs and complex permitting delays.45
Impact — Environmental groups and local communities lose their broad right to challenge industrial permits.6
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Response to Improving environmental protection through criminal law

21 Apr 2022

Polskie Górnictwo Naftowe i Gazownictwo S.A. (Polish Oil and Gas Company; hereafter: PGNiG) welcomes the opportunity to comment on the proposal for a directive on the protection of the environment through criminal law (COM (2021) 851 final). PGNiG recommends extending the scope of Article 9 so that it includes additional circumstances that may be regarded as mitigating circumstances. Specifically, we suggest adding the following wording as Article 9 (c): the offender acts in order to safeguard fundamental EU values included in the Treaty on European Union and the Treaty on the Functioning of the European Union. The aim of extending the scope of mitigating circumstances is to ensure that in exceptional situations there is a possibility to properly reconcile different values, i.e protection of the environment and fundamental EU values. The proposed additional category of mitigating circumstances could matter, for instance, in situations of energy supply disruptions that would put life and health of EU citizens at risk. In such case the disruptions could occur due to a decision of a supplier (e.g. foreign supplier during energy crisis) or because of technical failure of installations. In order to provide electricity and heating to citizens and in the absence of other options in the market, an energy company might need to use as emergency fuels or installations that would not meet environmental standards regarding emissions. Another example that could matter refers to extreme draughts and low water levels dramatically impacting cooling systems. In such situations, in order to prevent adverse effects on citizens there might be a need to release water from cooling systems of higher temperature than allowed according to environmental standards. In the above extreme situations protecting citizens could potentially lead to causing environmental damage and might be considered as a crime. However, in such situations mitigating circumstances should allow to take into consideration the value of health and life of citizens and acting to safeguard fundamental EU values.
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Polish oil company PGNiG seeks five-year delay to methane rules

15 Apr 2022
Topic — New EU regulation on monitoring, reporting, and reducing methane in energy sectors.
Message — PGNiG requests a five-year implementation deadline and more flexible technical definitions. They also suggest expanding permitted venting and flaring to ensure cost-effectiveness.12
Why — This would reduce the company's financial burden and simplify technical compliance requirements.34
Impact — Households and industry may pay more if costs are reflected in tariffs.56
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Response to Revision of EU rules on Gas

13 Apr 2022

Polskie Górnictwo Naftowe i Gazownictwo S.A. (Polish Oil and Gas Company; hereafter: PGNiG) supports objectives of the European Commission’s proposal for a regulation on common rules for the internal markets in renewable and natural gases and in hydrogen (COM(2021) 804), namely development of the low-emission and renewable gas market. Decarbonisation of gas sector should focus on promoting production of biomethane and hydrogen and development of their respective markets. Natural gas plays an important role as a transitional fuel on a pathway to climate neutrality by allowing to reduce emissions from solid fossil fuels. In view of the Russian invasion on Ukraine and dramatic changes in the gas market the key issue is ensuring diversified and secure supplies. Poland, with the support of the European Union, has put much effort into diversifying natural gas supplies. For this reason, natural gas will remain an important factor supporting the energy transition. Commission’s proposal for a regulation (COM(2021) 804) requires further work in order to prevent adverse effects on the functioning of the EU energy market. Highlights of the position: • While regional approach to storage obligation is welcome, it should not result in limiting existing measures at a Member State level. Therefore, a clarity is necessary that the requirements referring to regional storage mechanism do not apply to Member States level measures (Article 67 of the proposed legislation, adding new Article 7b to Regulation 2017/1938). • Transmission tariff discounts for natural gas at connections with LNG and storage facilities on grounds of security of supply need to be introduced to the draft regulation to provide for the legal certainty that the already existing discounts are applicable (Article 16). • Further clarification needed for mechanisms compensating the reduced income of a transmission system operator as a result of the reduction of transmission tariffs for low-emission and renewable gases (Article 16). • Ensuring gas quality in case of cross-border coordination (Article 19) and in case of cross border flows of blends of up to 5% of hydrogen (Article 20). • Further clarifications needed as regards EU DSO entity (Articles 36 and 37). • Further clarification needed as regards the scope of information that the Commission has the right to request (Article 59). • The solidarity compensation mechanism should not lead to overcompensation for unused gas or ex post questioning of the agreed costs (Article 67, amending Article 13 of Regulation 2017/1938 on security of gas supply). The full opinion of PGNiG is attached to this general statement, including comments on specific provisions that require further attention in the legislative process.
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Polish PGNiG warns EU gas rules threaten energy security

12 Apr 2022
Topic — Revision of EU rules to integrate renewable gases and hydrogen into the market.
Message — PGNiG demands natural gas remains a transition fuel and rejects banning long-term contracts. They argue infrastructure costs for new gases must not fall on existing gas undertakings.123
Why — This would protect existing gas assets and lower entry costs for hydrogen.4
Impact — End consumers face higher energy bills if renewable gas development costs are passed on.5
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

GENERAL COMMENTS • Reducing emissions in buildings should be carried out in the most cost-effective and technically feasible way possible, without excessive socio-economic burden. It should be ensured that the process of buildings’ renovation takes into account the needs and interests of groups vulnerable to energy poverty, each Member State’s (MS) development level as well as existing infrastructure. This is even more important as the EU economy still struggles with the effects of the COVID-19 pandemic, just aggravated by turmoil resulting from Russian invasion of Ukraine. • Well-developed and widely available solutions, such as natural gas from credible sources should be considered as key in the transition to a more efficient and low-carbon building stock in the EU. In the environment of tight energy supplies, natural gas has an essential role in the energy mix as a flexible and non-intermittent source of energy supplying continuously and reliably households, industry and the power generation. Member States should be able to take advantage of the opportunities for green transition offered by this low emission resource. • National policy frameworks should enable Member States to plan renovations of their building infrastructure according to their specific needs and in line with the overall climate neutrality objective. Given the varying nature of obstacles across Member States, a largely one-size-fits-all approach based solely on renewable energy sources would be too prescriptive. Even if zero emission solutions are binding for 2050, MS should be free to implement appropriate measures to reach this goal, taking into account their starting points and local conditions.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

PGNiG (Polish Oil and Gas Company) welcomes the opportunity to contribute to the Commission’s preparation of an impact assessment for the revision of EU waste framework. HIGHLIGHTS OF THE POSITION • Aims of the initiative should be extended in order to include a promotion of a priority principle for secondary anthropogenic raw materials which support the protection of natural resources. Essentially, the principle means the replacement of natural resources with materials of anthropogenic origin when it is justified from sustainable and economic perspective. • Regulatory measures should include simplifying procedure of granting the status of a by-product through a modification of a requirement concerning the certainty of further use of an object or a substance. Please see the attached document for more details.
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PGNiG urges flexibility for biomass fuel reporting rules

11 Jan 2022
Topic — The consultation concerns updated rules for monitoring and reporting greenhouse gas emissions from biomass.
Message — PGNiG supports postponing new sustainability criteria for biomass under the EU carbon trading scheme. They also propose allowing fuels bought in 2022 to be used in 2023 if technical failures occur.12
Why — This would help the company avoid higher costs from carbon emission charges.3
Impact — Environmental groups lose as the delay weakens the immediate enforcement of sustainability standards.4
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Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

GENERAL COMMENTS: • PGNiG highlights that some Member States due to national circumstances (e.g. Poland) still rely heavily on coal. PGNiG is actively involved in transformation of district heating by replacing coal plants with natural gas-fired high efficiency cogeneration units. • Due to national circumstances, in Poland natural gas is the only viable and effective solution with regard to emissions reduction in the district heating. The currently assessed potential for biomethane production in Poland is 4 bcm/year, which is not enough to supply all district heating exclusively with biomethane, therefore the role of natural gas in the short and medium term is essential. • Taking into account the importance of providing uninterrupted heat supply to end customers, PGNiG calls for providing realistic timeframe for increasing the RES share in district heating. • PGNiG is concerned about proposed changes with regard to the definition of ‘high efficiency cogeneration’ as proposed definition excludes a significant volume of coal-fired CHP capacity, and will results in difficulties with regard to investments in district heating systems considered as efficient in accordance with current legislation. In consequence, an urgent need to replace significant capacity will occur. The phase-out of large coal-fired capacity within a short period of time will result in energy shortages. Therefore, in order to avoid energy (in particular heat) supply distortions, there is a strong need to upgrade inefficient installations to the status of ‘high-efficiency cogeneration’. • PGNiG calls for smooth transformation of district heating – in particular with regard to the application of 270g CO2/kWh criterion, which should be introduced no earlier than 2030. Such an approach will allow for appropriate preparations for necessary investments and mitigation of negative socio-economic consequences of the transition. • PGNiG is concerned about the proposed changes regarding to the methodology of calculating energy savings, and in particular with the proposed exclusion of accountability of energy savings resulting from direct combustion of fossil fuels (which include e.g. natural gas) from the energy efficiency target. • Stricter requirements concerning method for calculating energy savings and the exclusion of certain technologies should apply, if at all, only to the direct combustion of solid fossil fuels but not to all fuels, as technologies based on the use of natural gas are significant element of the energy transition towards a sustainable economy. • In order to allow MS to reap benefits of affordable and economically viable technologies such as natural gas, we call for a change in the provisions regarding the application of the "energy efficiency first" principle by gas DSOs to voluntary. • PGNiG is concerned about this provision as in many cases, network losses occur as a result of incidents caused by third parties, self-occuring and security aspects and the DSOs/TSOs ability to mitigate losses resulting from such events is negligible. Please find attached full version of PGNiG position.
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Response to Proposal for a Regulation on establishing a Climate Action Social Facility

18 Nov 2021

GENERAL COMMENTS • Social Climate Fund intends, inter alia, to support the integration of renewable energy sources. However, it is of key importance to ensure technology-neutral approach that will enable taking advantage of more affordable solutions such as low carbon technologies e.g. all types of hydrogen and biomethane/biogas. • The fund should not only tackle burdens in the sectors planned to be covered by the EU ETS, but also sectors already covered by EU ETS. It is crucial especially in the context of rising energy prices. Therefore, there is need to establish additional fund that will ensure minimizing the influence of increasing energy prices on individual customers and enterprises. • Taking into account the current increases in energy and fuel prices worsening the financial situation of the European citizens, especially in low-income countries such as Poland, we are concerned that the financial resources allocated to the fund may not be sufficient to cover the social burdens.
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

GENERAL COMMENTS • Defining compressed natural gas (CNG) and liquefied natural gas (LNG) as transition phase fuels and limiting infrastructure commitments only to LNG and until 1 January 2025 may result in a time-limited support for these technologies and hamper the development not only of the bioLNG and bioCNG sector, but also projects developed for mixtures of hydrogen and natural gas. • For the bioLNG and bioCNG sector development, it is crucial to ensure the development of CNG infrastructure, maintain the opportunity for the development of LNG infrastructure, including processing, production, distribution, transmission and storage under regulation and to provide adequate support (e.g. under “Guidelines on State aid for climate, environmental protection and energy 2022” - CEEAG). • The role of gaseous fuels should not be limited to transitional. LNG and CNG are mature, affordable and widely available fuels for EU citizens and business. Moreover, switching to natural gas as an alternative fuel in public, heavy-duty, maritime and inland waterway transport will provide the sector with an immediate and significant GHG emissions reduction. • In order to enable the full deployment of available technologies, it is crucial to ensure a level playing field between different alternative fuels, based on technology-neutral approach. • The necessity to provide an adequate number of publicly accessible LNG and CNG refueling points within the TEN-T core network and at TEN-T core ports should be clarified, taking into account that the development of LNG and CNG based transport requires the development of an alternative fuels infrastructure. • The European Commission should promote alternative fuels infrastructure development, including primarily LNG, CNG, hydrogen and biomethane/biogas by providing incentives such as support mechanisms. Financial instruments should create flexibility for Member States in terms of infrastructure planning and the use of EU funds. • The draft national policy framework for the development of the alternative fuels market required by the European Commission should enable Member States to plan their infrastructure according to their individual specifications and needs. • The support limitation for CNG and LNG may affect negatively for profitability of the gas DSO's investment on expansion of the gas network for building refueling points. The time of return on investment projects in the gas / energy sector is usually 20-30 years, during which the invested capital expenditures should be returned. Therefore the support limitation for CNG and LNG increases the investment risk for the undertaken and new projects. • If the gas distribution networks technically allows for transport hydrogen, then the direction presented in the project will create perspectives for the higher distribution network service demand.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

GENERAL COMMENTS • Increasing the share of renewable energy in the EU's gross final energy consumption may result in administrative, economic as well as technology burdens for energy sector. Therefore, it is of key importance to ensure technology-neutral approach that will enable taking an advantage of more affordable solutions such as low carbon technologies e.g. low-carbon hydrogen and biomethane/biogas. • The objectives included in the RED proposal such as decarbonization of the industrial and transport sectors will create a significant demand for hydrogen. Therefore, the only way for ensuring rapid and economically efficient decarbonization is to put in place measures that will allow for using low-carbon hydrogen to meet the objectives set out in the RED proposal. • The obligation to phase out support for electricity generation from biomass from 2026 onwards may cause difficulties in achieving RED targets. Therefore, current provisions on biomass should be maintained. • Considering the structure of district heating and cooling networks in Poland, RED proposal should propose an increase in funding for network modernization instead of expanding targets. Increasing the share of RES or waste in district heating and cooling from 1.0p.p. to 2.1p.p. will not only be economically and technically infeasible, but it poses the risk of destabilizing the system. • RED revision proposes an annual mandatory increase of 1.1p.p. on the national level, compared to the current 1.1 indicative target in the heating and cooling sector. As above, the target may be economically and technically difficult to achieve. Therefore it should remain indicative. • New RES targets for the transport sector should be implemented with flexibility in terms of tools and technologies, taking into account national policies and circumstances. • Natural and renewable gas with its infrastructure are reliable, flexible and low emission back-up for the intermittent RES. It should be a part of the transformation process to ensure cost effectiveness of the process. • The natural gas infrastructure, especially distribution gas network, will play a crucial role in energy transition. In order to meet RED targets, increased investments in gas network and the new approach of economical effectiveness calculation are necessary. • PGNiG intends to become one of leading producers of energy from RES in Poland by heavily investing in this area - over the next few years, beyond 2022, PGNiG is going to spend even as much as 880 mln EUR. • Following the market demand, PGNiG plans to be one of the leading providers of the RES solutions to its customers as a complementary offering to its core business.
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Response to Revision of the Energy Tax Directive

17 Nov 2021

PGNiG welcomes the possibility to comment on the ETD proposal. We believe that the revision of the ETD should take into account EU energy policy objectives as enshrined in Article 194 TFEU: security, competitiveness and sustainability. Moreover, it should contribute to the goals of the Energy Union: to give EU consumers – households and businesses – secure, sustainable, competitive and affordable energy. However, in order to completely fulfil these objectives, we suggest to consider the following recommendations in the proposal: • Cogeneration should be allowed to be exempted from taxation. • The possibility of exemption from excise tax for maritime and road transport should be maintained. • The ETD should be an instrument that incentivises the use of all lower-emission and low-carbon technologies and fuels. • The role of natural gas as a transition fuel towards climate neutrality should be reflected in the final revised ETD. • The ETD legislation, as of fiscal nature, should be adopted within unanimous decision-making procedure.
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Response to Carbon Border Adjustment Mechanism

15 Nov 2021

GENERAL COMMENTS: • Carbon leakage is already a reality and the risk is likely to increase in the view of the raising of the EU climate ambition. • Taking into account the increased EU climate ambition, there is a strong need to appropriately address carbon leakage in order to maintain level playing field for EU producers when competing domestically and on global markets. Current proposal does not foresee any measures for EU export. • PGNiG is concerned about proposed replacement of existing tools preventing carbon leakage with CBAM. If CBAM is designed to be complementary to existing measures, it will not negatively affect EU exporters in the sectors concerned. • CBAM needs to be complementary to existing measures on carbon leakage in particular free allocation of EUAs (art. 10b of the ETS Directive). Otherwise, lack of level playing field in the markets outside of the European Union can lead to relocation or replacement of activities from the EU to partner countries in the sectors to which CBAM would apply, as EU companies willing to exports goods to third countries would still need to bear the cost of EU climate policy, while their competitors not. This would lead also to export of emissions. • In order not to impose more burden on EU industry (which is already disadvantaged in international trade by the necessity to cover the costs of energy transition), CBAM should not be applied to primary energy inputs, as this could lead to extra costs for EU industry and further decrease of its competitiveness. • A level playing field would ensure that energy intensive industry remains in Europe and thus, will be involved in development of new technologies/solutions contributing to achievement of EU climate ambitions. Please find attached full version of PGNiG position.
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

PGNiG welcomes the possibility to comment on the proposal for a regulation amending Regulation 2019/631 as regards strengthening the CO2 emission performance standards for new passenger cars and new light commercial vehicles in line with the Union’s increased climate ambition (Cars Regulation). The revision of the Cars Regulation enhancing the environmentally-friendly solutions in transport sector sets ambitious targets for car manufacturers. While PGNiG supports efforts undertaken in order to limit emissions and achieve carbon neutrality, following recommendations aiming at mitigating potentially negative consequences for EU citizens and entities acting in transport sector might be beneficial for the final outcome of this legislative initiative. I. Using natural gas as a transport fuel The Cars Regulation refers to the emissions from new passengers cars and new light commercial vehicles. While the main objective is to attain 100% emission reduction, the path towards this aims as well as available methods are not provided. In this regard the role of natural gas as a transport fuel should be emphasised. Currently natural gas in form of CNG or LNG allows to significantly reduce the emissions in transport. Bearing in mind this characteristics the supply side of transport sector responded to environmental concerns producing more vehicles powered by CNG and LNG. Additional endeavours to provide a zero emission transport fuel based on natural gas for example in a form of bioCNG, bioLNG or hydrogen are being made. Before these alternative zero-emission fuels are being commercially used, the efforts of creating low-emission vehicles, like these powered by LNG or CNG, should be appreciated. On a path towards climate neutrality, the intermediate steps promoting the use of low-emission fuels should be envisaged. In this regard it is worth to consider providing a transitional period allowing LNG or CNG powered vehicles to be registered in the EU. Moreover, the importance of alternative zero emission fuels, like bioLNG, bioCNG or hydrogen should be explicitly mentioned in the Cars Regulation. II. Aligning the efforts in car manufacturing and transportation infrastructure The Directive 2014/94/EU on the deployment of alternative fuels has been adopted as a part of endeavours to reduce emissions in transport and incentivise creation of low-emission infrastructure. Many infrastructure projects related to alternative fuels such as CNG and LNG have been implemented based on this directive. The existing infrastructure as well as the availability of low-emission fuels should be the main factors driven the effective policy in transport sector. In this regard Cars Regulation should take into account ongoing infrastructural developments and promote the production of low-emission vehicles over vehicles powered by petrol, as well as stimulate innovative technical solutions based on vehicles powered by alternative fuels. Please find attached full version of PGNiG position
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Polish energy giant PGNiG urges support for gas in carbon reform

8 Nov 2021
Topic — Revision of the EU Emissions Trading System to meet higher climate targets for 2030.
Message — The company wants natural gas and storage included in the Modernisation Fund for energy resilience. They also oppose extending carbon trading to buildings and transport to prevent increased energy poverty.12
Why — This allows the company to secure subsidies for gas infrastructure and reduce compliance costs.3
Impact — Financial institutions would lose trading opportunities if the Commission restricts market speculation by banks.4
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Response to FuelEU Maritime

8 Nov 2021

General comments: • The Council of the European Union recognised the need to support the development of different alternative fuels (including LNG as a transitional fuel). • As stated in the Impact Assessment accompanying the proposal for regulation, LNG provides a good solution to air pollution issues, allowing reductions in SOx and NOx emissions. In the longer term, LNG can pave the way to the use of bio-LNG or e-gas, which would also offer climate-related benefits. • By investing in LNG-fuelled vessels now, ship owners can deliver immediate GHG benefits – up to 21% on a Well-to-Wake basis and 28%, Tank-to-Wake, including the impact of methane emissions. Moreover, compared to heavy fuel oil (which is currently most commonly used fuel in shipping), LNG-fuelled vessels emit up to 100% less PM, up to 80% less NOX and up to 100% less SOX. • There is a huge need of further progress to be made to ensure sufficient capacities for LNG bunkering facilities in maritime ports. To ensure predictability for investors, the EU should be guaranteeing that LNG will has a place in future shipping energy mix and will further be considered as an alternative fuel providing climate benefits. Further increase in the number of ships fuelled with LNG depends largely on the development of necessary infrastructure for LNG bunkering. • To reap benefits of LNG as a fuel for ships, the EU should be cooperating with partners all over the world to develop infrastructure necessary for LNG bunkering as LNG can be a viable option only if adequate bunkering infrastructure is available globally. • In view of the above, Liquefied Natural Gas should have a place in the fuel mix for maritime transport, in particular in transitional period. LNG as a transitional fuel and LNG advantages: • In June 2020, in its conclusions, the Council of the European Union recognised ‘the need to support the development of different alternative fuels for use in all segments of waterborne transport and to ensure adequate funding in support of research and development through public, private and EU financial instruments and grants with the aim to make available clean alternative fuels, including LNG as a transitional fuel, and the associated infrastructure, innovative technologies and sustainable ship designs’. It also reiterated ‘support for the clear vision for green and carbon-neutral ports, including the use of LNG as a transitional fuel’. • According to the Impact Assessment accompanying the proposal on the use of renewable and low-carbon fuels in maritime transport , LNG ‘provides a good solution to air pollution issues, allowing reductions in SOx and NOx emissions’ and ‘in the longer term, LNG can pave the way to the use of bio-LNG or e-gas, which would also offer climate-related benefits’. • Reffering to Sea-LNG CE Delft Study report , by investing in LNG-fuelled vessels now, ship owners can realise immediate GHG benefits – up to 21% on a Well-to-Wake basis and 28%, Tank-to-Wake, including the impact of methane emissions. These LNG-based assets can use non-fossil fuel methane such as Liquefied Biomethane (LBM) and Liquefied Synthetic Methane (LSM) with little or no modifications. • European Maritime Safety Agency also recognised the advantages of LNG as, compared to heavy fuel oil (with a share in the fuel mix about 72%), LNG-fuelled vessels emit up to 100% less PM, up to 80% less NOX and up to 100% less SOX. These advantages of LNG are crucial for human health and environment. • In view of the above, Liquefied Natural Gas should have a place in the fuel mix for maritime transport, in particular in transitional period. Please find attached full version of PGNiG position.
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Meeting with Kadri Simson (Commissioner) and

8 Nov 2021 · Gas market and security of supply framework.

Response to Revision of Non-Financial Reporting Directive

8 Jul 2021

In order to develop regulations which will contribute to fulfill the growing demand for sustainability information without unnecessary burdens for companies, we suggest to consider the following issues: • The sustainability-reporting standards should be included in the CSRD Directive. Adopting the sustainability-reporting standards in the delegated acts would undermine the role of the European Parliament and the Council. • Disclosures should focus on ‘material’ and relevant information. Companies must continue to be able to determine what information are material for their investors and other stakeholders. • A flexible approach is needed. Maintaining flexibility in the selection of information indicators that companies need to share would be more in line with the stakeholders needs. • Existing standards should be taken into account. Already existing frameworks, e.g. IPIECA’s Sustainability reporting guidance for the oil and gas industry should be taken into account. • Adapting to new requirements should be made in a cost-effective manner. Implementing new obligations should not significantly increased costs and excessive administrative burdens for companies. • Reporting obligations on forward-looking information should not affect commercially sensitive and confidential information. It should be taken into account that disclosure of forward-looking information may interfere with commercially sensitive information and/or confidential information. • Omission of the information in exceptional cases should be supervised. Companies should be supervised when omitting information to ensure transparency in the reporting. • Adaptation to single electronic reporting format regarding appropriate timeline. Adaptation to single electronic reporting format will be time-consuming so there should be realistic timeline for this process. • Refraining from imposing penalties and sanctions in the Proposal. Penalties included in the Proposal are too strict, taking into account the nature of the breach. • Compatibility with recently implemented and upcoming legislation. In order to ensure coherence and alignment between different EU legislation, clear policy planning framework with well-sequenced, realistic timelines is necessary.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

1 Jun 2021

In order to develop regulations which will contribute to the achievement of the EU’s climate and environmental objectives, we suggest to consider the following issues: • Compatibility and coherence with existing and upcoming legislation. Clear policy planning framework with well-sequenced, realistic timelines is necessary. • Considering the existing standards. Already existing frameworks, e.g. IPIECA’s Sustainability reporting guidance for the oil and gas industry should be taken into account. • Ensuring a realistic implementation timeline. The proposed phase-in of the reporting obligation is not enough for companies to make necessary and significant internal adjustments to comply. • Shorter reporting period of disclosing. The obligation to provide the key performance indicators in financial reports should be shortened to less than five reporting periods. • Rational time horizon of the CapEx Plan. The assumed time horizon of five years of the CapEx Plans should be shortened to provide reliable data.
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Response to Revision of certain procedural aspects of EU merger control

23 Apr 2021

Attached please find PGNiG's feedback.
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Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

5 Apr 2021

We welcome the possibility to comment on the initiative concerning Modification of the General Block Exemption Regulation for the European Green Deal and the Industrial and Digital Strategies. The initiative aimed at amending the Commission Regulation (EU) No 651/2014 of 17 June 2014 declaring certain categories of aid compatible with the internal market in application of Articles 107 and 108 of the Treaty (hereafter ‘the GBER’) and ensuring complementarity with the European Green Deal and Industrial and Digital Strategy should be assessed positively. In order to develop regulations which can enable the energy transition, we suggest the following remarks on the GBER. Highlights of the position: • GBER should allow for the possibility of granting aid in relation to investments involving the production, storage, distribution and transmission of renewable and low-carbon gases, in particular biomethane and hydrogen, including the use of blends of natural gas with renewable and low-carbon gases. Such aid would aim at swift GHG emission reductions. • A complex approach is necessary for integration of renewable and low-carbon gases projects, which should allow for expansion and adaptation of distribution networks, including connections for renewable and low-emission gas facilities, reverse connections between gas pipelines of different capacities and between DSOs and TSOs, as well as the expansion of gas pipelines to accommodate the transport of renewable and low-emission gases. • The overall notification thresholds, as set out in Article 4 of the GBER, should be defined per whole project in order to increase the support which might be granted to one or more undertakings when they engage in decarbonization activities. • Linking the State aid framework with technical criteria stemming from the Taxonomy Regulation would be highly unjustified. It would result in the reduction of the investment effort leading to decreasing the pace of decarbonization and would contradict principles of legal clarity and certainty. • In the field of technologies based on renewable and low-carbon gases, especially biomethane and hydrogen, the GBER should allow for the possibility of obtaining aid for research, development and innovation programs, both by entities (energy market participants) directly investing in such research, as well as through research clusters, business environment institutions and universities. • In order to ensure the coherence and completeness of the European Union law, the solutions that will be implemented in the GBER should be adequately reflected in the update of Guidelines on State aid for environmental protection and energy. Details of the position can be found in the attached document.
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Response to Revision of EU rules on Gas

10 Mar 2021

PGNiG welcomes the opportunity to comment on the Commission’s Inception Impact Assessment as regards the revision of EU rules on market access to gas networks. The planned revision of EU should include only targeted changes in the regulatory framework in order not to undermine the benefits of the Third Energy Package. The rules in place since 2009, with amendments and complementing them network codes, proved to serve well the development of the energy market and the regulatory regime supporting competition on the market should not be changed. Their full implementation is the key action in terms of guaranteeing the fully functioning internal market for natural gas. In particular, current rules governing LNG terminals serve the development of this market and provide necessary stability for bringing diversification of supply sources. The targeted revision of rules should aim at the main goals identified in the IIA, i.e. creation of the market for renewable and low-carbon gases (bio-methane, hydrogen) in order to contribute to increased EU climate ambition of 55% greenhouse gas emissions reduction by 2030. Still, the revision should be fully in line with the pillars of EU energy policy, i.e. security, competitiveness, sustainability and achieve a proper balance between them. The revision of rules should take into account specificities of different markets on their way towards climate neutrality, namely decreasing high dependency on coal, economic importance of energy-intensive industry (e.g. refineries, fertilisers, steel making) and recent costs incurred for infrastructure development including the EU’s PCIs. In some Member States natural gas will play an important role as a transitional fuel longer than in other Member States as natural gas delivers immediate emission reductions and is the only economically and technically feasible way to meet increased targets of GHG emission reduction. The use of natural gas will allow a swift switch away from coal. Moreover, it will not lead to lock-in as natural gas and gas infrastructure serve scaling up of hydrogen and bio-methane production and enable increased deployment of renewable sources of energy by bringing backup capacity. Therefore, we share Commission expectation that biogas, bio-methane, renewable and decarbonized hydrogen will contribute to energy mix in 2050. Moreover, we also share the Commission analysis that abated natural gas can also contribute to carbon neutral energy mix. HIGHLIGHTS OF THE POSITION (details in the attached document) • Better integration of markets and infrastructure should encourage developing gas storage serving natural gas as well as renewable and low-carbon gases. • The rules introduced by the Third Energy Package should be applied to the hydrogen market. • Technology neutral approach to hydrogen is necessary for market uptake and should be applied both in supporting of infrastructure development and in designing market rules. • Cooperation with third countries should be based on following similar market and sustainability standards. In particular, imports of renewable and low-carbon hydrogen to the EU should follow the market rules of the Third Energy Package. • Regulatory changes, including for LNG terminals, should be limited only to issues directly connected with renewable and low-carbon gases and the third party access (TPA) exemptions should be applied restrictively in order not to disrupt competition. • To guarantee that customers would not be affected by disruptions caused by changing gas quality, there should be clear technical criteria for bio-methane and hydrogen based on the NRA decision.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

• TEN-E should continue to support natural gas projects as it could play an important role in delivering clean and affordable energy in the transitional period; • The significant development of clean gases influences future role of the existing natural gas infrastructure as it may be used to transport renewable gases and hydrogen and back-up the variable power generation; • Increase in demand for natural gas should effect with storage infrastructure development (such as cavern gas storage). It will ensure stability of the sector's operation and will increase the degree of independence from external gas suppliers; • Priority corridors presented in the 2013 TEN-E Regulation such as North-South Gas Corridor or the Baltic Energy Market Interconnections (BEMIP) have not yet been completed. Their completion is crucial from the point of view of the functioning of the internal energy market and the implementation of the gas hub project in the CEE. Therefore cross-border connections included in priority corridors should be still eligible for PCI and PMI status as well as EU financing; • Considering that the hydrogen market is in the early development stage, the main effort should be put on the uptake of hydrogen as fuel and market development. Therefore the principle of technology neutrality needs to be applied. • According to the Annex II, Smart Gas Grid refers to the equipment or installation aiming at enabling and facilitating the integration of renewable and low-carbon gases (including biomethane or hydrogen) into the network which is of key importance. However, the whole Regulation should emphasize also adaptation of the network to a distributed generation model as well as transport of blends of natural gas with hydrogen or with biomethane. It is essential to provide the clarity on this point throughout Regulation and Annexes text. • Moreover, a complex approach is necessary for integration of renewable and low-carbon gases projects, which should allow for expansion and adaptation of distribution networks, including connections for renewable and low-emission gas facilities, reverse connections between gas pipelines of different capacities and between DSOs and TSOs, as well as the expansion of gas pipelines to accommodate the transport of renewable and low-emission gases. • Any modifications of criteria for PCIs should not compromise goals of energy security and further development of internal energy market, market integration, security of supply, competition and sustainability should remain the criteria for gas PCI selection; • According to proposed provision in the TEN-E regulation revision, main condition for PMIs status is a high level of alignment with the EU internal energy market in particular in terms of EU gas market legislation. We fully support that and in our opinion requirements in this area should be even strengthened, to avoid grating PMI status to projects that would result in a distortion of competition, thereby strengthening the scenario of the dominant supplier.
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PGNiG urges EU to prioritize cost-effective methane reduction rules

26 Jan 2021
Topic — The EU is developing legislation to monitor and reduce methane emissions in energy.
Message — PGNiG calls for measures that are not overly prescriptive to avoid excessive financial burdens. They recommend creating a toolbox of actions based on industry experience before finalizing legislation. Requirements should be tailored to specific business profiles and sectors.123
Why — This approach would protect the company from high compliance costs and rigid technical mandates.45
Impact — High implementation costs could lead to energy poverty and higher prices for consumers.67
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Polish giant PGNiG slams over ambitious EU heating benchmark cuts

4 Jan 2021
Topic — This consultation focuses on the updated benchmarks for free emission allowance allocations.
Message — PGNiG requests excluding biomass from benchmark calculations to reflect actual sector conditions. They urge the Commission to recognize natural gas as a vital transition fuel.12
Why — This would preserve free allowances and protect financial resources for necessary investments.3
Impact — Residents face higher heating costs, potentially driving them toward polluting solid fuels.45
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

PGNiG S.A., on behalf of PGNiG Group, welcomes the opportunity to comment on the draft Commission Delegated Regulation supplementing the taxonomy regulation. Access to finance is the key for a successful and cost-efficient energy transition. It conditions the achievement of EU climate neutrality goal as well as the recently revised 2030 GHG emission reduction target. The taxonomy delegated regulation needs to provide the financial sector with a clear framework enabling investments that contribute to emission reduction. It needs to be comprehensive, take into account different national circumstances and starting points, do not cause excessive administrative burden and allow for all industries to contribute to emission reduction. It also needs to provide the framework that will allow for financing the economic development and job creation, which will be in particular important during the post-COVID-19 recovery. Therefore, we cannot allow to put any industries that can contribute to energy transition, in particular natural gas industry, on the side-lines. Natural gas industry as the transitional activity can and must contribute to energy transition. The attached file includes detailed remarks regarding Annex I: • Generation of electricity, heat/cool and cogeneration from gaseous fuels (4.7, 4.19, 4.23); • Transmission and distribution networks for gaseous fuels (4.14); • Storage of hydrogen (4.12); • Manufacture of hydrogen (3.9); • Manufacture of equipment for the production of hydrogen (3.2); • Generation of heat/cool and power and cogeneration from bioenergy (4.8, 4.20, 4.24); • Manufacture of biogas and biofuels for use in transport (4.13); • Anaerobic digestion of sewage sludge and bio-waste and landfill gas capture and utilisation (5.6, 5.7, 5.10); • Transport (6.3, 6.6, 6.10, 6.11, 6.12, 6.15, 6.16) and • regarding Annex II (4.9, 4.19, 4.23)
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PGNiG Urges Tailored EU ETS Rules to Protect Industry

26 Nov 2020
Topic — Revision of the EU Emissions Trading System to align with 2030 climate targets.
Message — PGNiG requests maintaining free allowances for district heating and gas extraction to prevent carbon leakage. They also oppose including waste incineration in the ETS, arguing it would unintentionally increase landfilling.123
Why — This would protect their profitability by lowering compliance costs and maintaining their competitive position.45
Impact — Citizens in coal-dependent regions may face higher energy bills if modernization funds are insufficient.6
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Response to Addressing distortions caused by foreign subsidies

29 Oct 2020

Acknowledging growing concerns about the distortions caused by foreign subsidies within the Internal Market, the initiative undertaken by the Commission to present proposal of regulation in order to address these interventions generally and also in the specific cases of acquisitions and public procurement is highly welcomed. Since the details of proposed solutions have not been presented, it suffices to support this initiative and provide general remarks on the directions for further steps of its development. Effective functioning of measures addressing distortions caused by foreign subsidies will be enhanced by the implementation of following aspects: o Consistent and ambitious legislative action; o Ensuring holistic approach towards multiple distortions caused by foreign interventions, in particular consistent enforcement of current EU legal framework; o Addressing foreign legislative solutions which might adversely influence competition in the internal market. European Commission’s White Paper on levelling the playing field as regards foreign subsidies indicated significant regulatory gaps in current EU law system concerning subsidies which are being granted by foreign states. As repeatedly emphasised, foreign subsidies might lead to significant distortion of competition as well as adversely affect the creation of level playing field for all undertakings active on the internal market. Due to very significant risks posed by foreign subsidies it is indispensable to introduce adequate measures which are capable of preventing unwanted interferences in the internal market. The only suitable, effective and proportionate measure to address these threats for functioning of the internal market is to take legislative action at EU level. Both non-regulatory approach and international rule making are not adequate and will very likely fall short of meeting expectations. Therefore the introduction of one or more regulations containing the solutions provided in White Paper will be very welcomed. Introducing legislative measures constitutes the only real impact capable of filling in current regulatory gaps in regard to acquisitions of EU undertakings, public procurement procedure and other market distortions.
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Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

14 Oct 2020 · Meeting with the CEO of Polish Oil & Gas Company (PGNiG S.A.) - exchange of information

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

21 Sept 2020

GENERAL COMMENTS: • Natural gas is a bridge from coal to renewables and hydrogen. Especially in MS like Poland whose economy is to a large extent based on coal, role of gas is crucial in the process of energy transformation toward clean sources of energy. • It is of key importance to ensure that any possible increase of RES target is set only after a thorough impact assessment and in a technology neutral manner. The applied solutions should be consistent with other policy measures, and all forms of renewable and low-carbon hydrogen should be considered eligible. • Picking winners could jeopardize the potential of different technologies (biomethane, ‘green’ hydrogen, ‘blue’ hydrogen) for providing cost effective emission reduction and scaling up the market. In view of the above, technology specific targets should be avoided. • The energy transition will require some Member States (e.g. Poland) to make a greater effort than others as due to historical national circumstances these MS depend heavily on coal. Increasing costs of transition due to more ambitious policy, would require additional support, in particular for those MS facing highest challenges of transition. • Deployment of natural gas infrastructure (e.g. distribution grids or gas storage facilities) will facilitate development of renewable and low-carbon gases. • Therefore, it is fundamental to ensure and implement enabling regulatory framework that will allow to make necessary investments in gas infrastructure. • Access to finance and the EU funding is crucial. Ongoing works on taxonomy must include gas as a transitional activity. Gas should not be excluded from Cohesion Policy (Cohesion Fund, ERDF), TEN-E, CEF and other instruments (JTF). Please find attached full version of PGNiG position.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

• There is no one-size-fits-all approach for companies operating in various industries. • Each industry has its own unique characteristics and determinants. • Developing detailed reporting guidelines should take into account determinants that were pointed out above, as it will help to assess if activities can be considered environmentally sustainable according to the EU taxonomy. • It is of key importance to ensure that there will not appear any excessive administrative burden for reporting entities, resulting from any possible additional reporting. • Moreover, establishing any regulations relating to additional reporting cannot cause risk of overlapping requirements. • Companies have sufficient knowledge on the information needs of their stakeholders. Therefore, a sufficient level of flexibility should be provided for the companies by the delegated regulation to manage and disclose the specific information within the framework set out by the Taxonomy Regulation. • Activities that are qualified as environmentally sustainable according to Taxonomy Regulation are associated with the development and deployment of new technologies such as hydrogen, biomethane or alternative fuels such as LNG and CNG. Due to the development of new technologies in various areas of the economy, detailed indicators and methodologies may need to be periodically updated. • Taxonomy Regulation includes also the ‘transition activities’, which should include the use of natural gas. Therefore, reporting of data should be fit for purpose, which can be ensured only by the sufficient level of flexibility instead of prescriptive character. • Existing legal requirements for non-financial reporting are flexible and allow issuers to adapt their communications to reflect the actual information needs of the market and investors which is of key importance not to cause any additional costs for companies and threatening to significantly over-regulate the capital market.
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Response to Offshore renewable energy strategy

13 Aug 2020

• Offshore RES can contribute to green recovery as well as long-term sustainable and inclusive growth by boosting jobs and economy activity which is of key importance especially at a time when economy is struggling with the effects of the COVID-19 pandemic. • Reduction of GHG emissions should be performed in the most cost-efficient manner involving well-developed and widely accessible solutions. • Offshore may become an important pillar of clean energy transition, however in the view that RES are highly weather dependent it cannot be treated as a silver bullet of the transition. • Natural and renewable gas with its infrastructure is reliable, flexible and low emission back-up for the intermittent RES. It should be a part of the transformation process to ensure cost effectiveness of the process. • Gas grid provides security of energy supplies and in the future, energy from offshore can be used to produce hydrogen which can be effectively transported by the gas grid. • Offshore RES can be promoted only with reliable and flexible mechanisms to support the step up and long-term sustainable technology development as well as creating market which will enable achievement of a scale effect. • PGNiG intends to become one of leading producers of energy from RES in Poland by heavily investing in this area - over the next few years, beyond 2022, PGNiG is going to spend even as much as EUR 1bn.
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PGNiG urges flexible and cost-effective EU methane emission rules

5 Aug 2020
Topic — The EU is creating a strategy to lower methane emissions across energy and agriculture.
Message — PGNiG requests flexible rules to ensure emission reductions are performed cost-efficiently. They seek standardized measurement methods and legislative support for biogas and waste-to-energy. They also propose excluding waste-to-energy plants from the EU emission trading scheme.123
Why — Flexible rules allow the company to avoid high costs for small emission reductions.45
Impact — Climate advocates lose because some methane leaks will persist if repairs aren't profitable.67
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Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

GENERAL COMMENTS • Currently, transport sector accounts for a quarter of the EU greenhouse gas (GHG) emissions and this value continues to grow. • Natural gas (LNG/CNG) powered vehicles reduce GHG emissions of approximately 20-22% (sum of CO2, CH4 and N2O) and produce three times less NOx compared to gasoline or diesel vehicles. LNG-fuelled ships emit up to 100% less PM, up to 80% less NOX and up to 100% less SOX. • Shift to natural gas as alternative fuel for public, heavy-duty, maritime and inland waterway transport will provide the sector with immediate and significant GHG emissions reduction. • LNG and CNG are well-developed and affordable solutions and widely accessible for the EU citizens and businesses. • Gas industry can also provide solutions for zero-emission transport based on clean hydrogen and biogases (in particular biomethane). • Development transport based on LNG and CNG fuels requires expansion of alternative fuel infrastructure. Therefore: 1) LNG and CNG infrastructure should remain in the scope of the Directive on the deployment of alternative fuels infrastructure, as an alternative fuel essential for reducing GHG emissions in the transport sector. 2) For alternative fuel infrastructure deployment, there should be created level playing field between the different alternative fuels ensuring technology neutrality. 3) The development of alternative fuels infrastructure (including CNG/LNG) as well as of new solutions (e.g. hydrogen and biomethane), in particular regarding the decarbonisation of transport should be eligible for the EU funding including cohesion policy and Just Transition Fund. Please find attached full version of PGNiG position.
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Response to Strategy for smart sector integration

8 Jun 2020

• Upcoming EU energy sector integration measures should leverage available merits of the EU energy system in order to ensure sustainable and cost-effective transition to low-emission economy and then enable accomplishment of the EU climate neutrality objective. • Natural gas could be one of the main keystones of the sector integration process, as a back-up tool and binding factor within diverse components of integrated energy sector in the EU. • Natural gas can be a cost-effective keystone supporting electrification (e.g. backup for RES and as a storage element) esp. for hard to abate sectors such as maritime, aviation and heavy duty transport as well as energy intensive industries. • There is a need to stimulate the development of high efficient heating systems (CHP technology) and individual heating devices as an important element of transformation, with the usage of natural gas as a bridge fuel from coal to renewables and hydrogen in the future. • Natural gas infrastructure can bind elements of local (also dispersed) energy systems using biogas and bio-methane as impulses for the expansion of prosumer energy (also under intention of integration of waste and energy sectors) ought to be perceived as technical enabler of deployment of low-carbon gases, i.e. bio-methane, biogas, syn-gas and hydrogen. • Establishing targets as to low-carbon gases’ share within energy sector would be counterproductive and would cause adverse effects. • We would recommend to adopt a wide scope prospect of clean hydrogen utilization in terms of an integrated energy sector. We support development of technologies for clean hydrogen as well as for blending hydrogen with natural gas to enhance transition value to the energy sector’s transition aims.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

GENERAL COMMENTS: • Natural gas can deliver significant emissions reduction in heating sector – up to 33% of CO2, 80% of NOx, and almost 100% of SOx and PM. • The development of natural gas network provides EU citizens access to natural gas and enables them to replace inefficient coal boilers with gas-fired boilers. • Gas industry has a key role to play in achieving the objectives of the Renovation Wave initiative by improving energy efficiency and ensuring affordability of Europe’s ageing building stock. Therefore, the access to the EU financing should be granted for gas based heating under renovation wave to address both energy poverty and air pollution. Please find attached full position of PGNiG.
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Response to A EU hydrogen strategy

8 Jun 2020

• Hydrogen should be considered as a low hanging fruit towards clean economy; • Hydrogen strategy should support technology-neutral approach by comprising all clean hydrogen production pathways including production of low-carbon hydrogen based on natural gas „blue hydrogen”, especially in the transitional period; • Gas infrastructure can be used in the future to transport mixture containing hydrogen, after necessary adaptation; • GHG emissions can be significantly reduced by blending natural gas with hydrogen. However, the process of injecting blends into gas infrastructure needs to be correlated with the gradual development of distribution, transmission and storage infrastructure fit for different blends as well as revision and deployment of such regulation; • The regulatory framework for clean hydrogen as an energy carrier in connection with the strategy for smart sector integration should be created and adapted to existing ones and implemented; • We are already taking an advantage of the opportunities provided by clean hydrogen as PGNiG has announced a hydrogen programme designed to enable the production of clean hydrogen from natural gas and RES.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

• TEN-E should continue to support development of natural gas transmission infrastructure as natural gas could play an important role in delivering clean and affordable energy in the transitional period; • The significant development of clean gases influences future role of the existing natural gas infrastructure as it may be used to transport renewable gases and hydrogen and back-up the variable power generation; • Any modifications of criteria for PCIs should not compromise goals of energy security and further development of internal energy market; market integration, security of supply, competition and sustainability should remain the criteria for gas PCI selection; • Future TEN-E framework should support the completion of missing links; • Gas projects should be further eligible for granting PCI status and CEF funding; • TEN-E should facilitate obtaining a PCI status for projects with the involvement of EU Member State and Energy Community Contracting Party.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

8 May 2020 · Polish gas, hydrogen and biogas developments

Response to Minimum standards for benchmarks labelled as EU Climate Transition and EU Paris-aligned Benchmarks

6 May 2020

• In order to allow for companies to transform their energy mixes and to align with the objectives of Green Deal Article 11 (d)-(e) needs to be properly adjusted. • Moreover, in order to take full advantage of the natural gas contribution to emission reduction as well as to enabling clean and decarbonized gases, Article 11 (f)-(g) should be removed or adjusted. • A separate category for ‘transition activities’ should be considered as an option for activities based on natural gas. • The emission threshold set out in Article 11 (g) needs to be reconsidered.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

GENERAL COMMENTS • Currently, transport sector accounts for a quarter of the UE’s greenhouse gas (GHG) emissions and this value continues to grow. • Natural gas (LNG/CNG) powered vehicles reduce GHG emissions of approximately 20-22% (sum of CO2, CH4 and N2O) and produce three times less NOx compared to gasoline or diesel vehicles. LNG-fuelled ships emit up to 100% less PM, up to 80% less NOX and up to 100% less SOX. • Shift to natural gas as alternative fuel for public, heavy-duty, maritime and inland waterway transport will provide the sector with immediate and significant GHG emissions reduction. • LNG and CNG are well developed and affordable solutions and widely accessible for EU citizens and businesses. • Gas industry can also provide solutions for zero-emission transport based on clean hydrogen and biogases. • Development transport based on LNG and CNG fuels requires expansion of alternative fuel infrastructure. Therefore: 1) LNG and CNG infrastructure should remain in the scope of the Directive as an alternative fuel essential for reducing GHG emissions in the transport sector. 2) For alternative fuel infrastructure deployment, there should be created level playing field between the different alternative fuels ensuring technology neutrality. 3) The development of alternative fuels infrastructure (including CNG/LNG) as well as of new solutions, in particular regarding the decarbonisation of transport should be eligible for EU funding.
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Response to Climate Law

30 Apr 2020

General comments: 1) Climate neutrality target for 2050 should remain at EU level [art. 2(1)]. 2) A thorough impact assessment is needed to address the real impact of increasing reduction targets for 2030 up to 50-55%, especially in the context of COVID19 outbreak and its repercussions on EU economy [art. 2(3)]. 3) The trajectory after 2030 should be considered an essential decision and as such should be made with utmost consideration under the ordinary legislative procedure [art. 3 and 9]. Please find attached full version of PGNiG position.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

• Assessment for the purpose of taxonomy scheme should be constituted with a view to natural gas transition value and long-term contribution to decarbonization objectives. • Technology neutrality principle within classification criteria in the future Taxonomy Delegated Regulation would ensure effective and sustainable switch to climate neutral economy with no adverse repercussion for stability and competiveness of the EU economy. • Taxonomy Delegated Regulation should establish a catalog of “transition activities” to accelerate the EU decarbonization strategy in a cost effective way. • We would suggest flexible approach as for thresholds and criteria of taxonomy scheme. • Taxonomy scheme needs to consider social and local dimension of decarbonization strategy.
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Response to FuelEU Maritime

24 Apr 2020

Please find PGNiG feedback attached.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

Please find attached PGNiG position on inception impact assessment concerning revision of the Industrial Emissions Directive.
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Response to Access to Justice in Environmental matters

3 Apr 2020

• Because of role of gas as a transition fuel, proposed Revision of EU procedural rules under Aarhus Regulation should enable sustainable investments and projects in regards to utilization of natural gas. • Extending the timeline to challenging acts and decisions for qualified NGOs should not negatively influence the investment processes and not undermine legal certainty as well as competences of national authorities. • Future measures should be compliant with proportionality principle and should provide a balanced approach.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

• Taxation of energy products should comprehensively consider all the aspects of EU energy transition ambitions and address a significant role of natural gas as a transition fuel towards a carbon neutrality. • Fiscal measures as instrument of adjustment the EU taxation legislation with the EU environmental goals should be formed in compliance with three pillars of EU energy policy equally: competitiveness, security and sustainability. • Future taxation of energy incentives needs to take into account a wide scope of alternative fuels facilitating sustainability of EU energy transition policy. • The right legal basis for any legislative initiative concerning ETD remains art. 192 sec. 2 TFEU.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

Please find attached PGNiG position on inception impact assessment concerning carbon border adjustment mechanism.
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Response to Climate Law

6 Feb 2020

PGNiG S.A. welcomes the opportunity to comment on the European Commission roadmap of Climate Law, which will be proposed by March 2020. We support efforts aimed at reducing emissions of greenhouse gases, however we point out the necessity of addressing climate change in a technology-neutral and cost-efficient way. Especially we find natural gas as the low-hanging fruit in transition towards cleaner energy. Natural as can bring significant emissions reduction as its wider use in power and heat sectors not only allows to cut emissions, but also supports the development of intermittent renewable energy sources. Natural gas can also significantly contribute to emissions reduction in transport sector. Therefore natural gas is essential for smooth transition to cleaner energy and should continue to play a vital role in the EU energy mix. General recommendation Natural gas can be a backbone of energy transition towards cleaner future as well as can play a vital role in delivering clean energy to Europeans. Particularly, natural gas can contribute to achievement of ambitious climate and energy objectives by: • providing efficient and clean source of electricity and heat for European customers as well as for industry, supporting its competitiveness whilst ensuring that business contributes to transition; • providing support for intermittent RES installations, fostering integration of these installations into relevant grid; • delivering efficient and innovative technologies which can be used for the purpose of energy storage as well as for the new source of clean energy (e.g. power-to-gas, bio-methane, biogases and decarbonized hydrogen); • helping other industries to get involved to energy transition by immediate providing low emission technologies for such sectors as road and maritime transport. As natural gas supports the development of RES, as well as contributes to GHG emissions reduction, we are of the opinion that following natural gas related investments should be eligible for EU financing at least in the following areas: • replacing coal-based heating system for climate mitigation purposes; • investments in distribution and transport of natural gas substituting coal; • investments related to clean vehicles as defined in art. 4 of Directive 2009/33/EC. Please find full PGNiG position attached.
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PGNiG seeks clearer rules for carbon allowance adjustments

9 Jul 2019
Topic — This consultation revises rules for free allocation of allowances in the EU ETS.
Message — PGNiG requests clearer timelines for adjusting free carbon allowance levels. They suggest specific wording to avoid misinterpretations of activity changes. They also seek clarity on rules for fluctuating industrial production levels.12
Why — Greater legal clarity would help the company avoid costly regulatory misinterpretations.3
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Meeting with Adam Romanowski (Cabinet of Vice-President Maroš Šefčovič)

1 Jul 2019 · State of the Energy Union

Polish Gas Giant Urges Inclusion in Carbon Leakage List

21 Dec 2018
Topic — Defining which industrial sectors qualify for free emission permits until 2030.
Message — PGNiG requests that natural gas extraction be added to the protected list. They argue the current assessment uses flawed data and methodology to calculate trade intensity.12
Why — Inclusion would grant the company free emission allowances, lowering its regulatory costs.34
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Response to Urban Mobility in the EU

18 Dec 2018

PGNiG position on evaluation roadmap ‘Urban Mobility in the EU’. PGNiG welcomes the possibility to comment on the evaluation roadmap ‘Urban Mobility in the EU’. We are actively involved in urban mobility development, as we support efforts to promote clean vehicles, especially vehicles fueled with natural gas. Urban mobility faces many challenges such as e.g. air pollution, which has an adverse effect on the human health of European citizens. The International Agency for Research on Cancer has classified air pollution in general, as well as PM as a separate component of air pollution mixtures, as carcinogenic. Moreover, according to the European Environment Agency report , PM2,5 concentrations in 2015 were responsible for about 391 000 premature deaths originating from long-term exposure in EU. The estimated impacts on the population in EU countries of exposure to NO2 concentrations in 2015 were around 76 000 premature deaths. Therefore, PGNiG strongly supports efforts to improve air quality, and consequently to reduce number of premature deaths in Europe caused by poor air quality. As development of cities brings with it increase in the number of vehicles, air quality improvement becomes more and more pressing issue. In our view natural gas (especially CNG/LNG), can greatly contribute to the air quality improvement, especially in cities, which grapple with traffic congestion and high concentration of pollutants. LNG/CNG in comparison to conventional vehicle fuel has a lower environmental impact. It reduces emission of carbon dioxide, nitrogen oxides, lead, but, eliminates Sulphur dioxides. Gas powered vehicles emit approximately three times less NOx less than gasoline vehicles and particle number emissions of gas vehicles are 15-70 times lower than those of gasoline vehicles. Similar effects are possible to achieve in comparison to Diesel engines. Additional advantage that comes with promotion of CNG and LNG as vehicle fuel is long-term positive effect. Extremely low level pollutants emission through years of CNG/LNG vehicles’ operation is confirmed in long term measurements by Portable Emission Measurement System (PEMS). Therefore, we are of the opinion that mature and widely available vehicles fueled with natural gas should be considered as low-hanging fruit of transition towards air quality improvement. In the view of above, we would like to highlight the importance of natural gas powered vehicles development. Wider use of natural gas in urban mobility, may reduce considerably level of pollutants causing respiratory diseases such as cancer, asthma, COPD (Chronic Obstructive Pulmonary Disease) or any other. We are of the opinion that immediate measures must be taken to ensure protection from adverse impacts on environment and risks to human health. In particular well developed and available technologies such as CNG/LNG can play vital role in air quality improvement. To tackle the problem of air pollution, funding for natural gas technologies development should be provided. Therefore, all necessary measures shall be taken to support natural gas technologies. In particular art. 6 (1) h of proposed regulation on the European Regional Development Fund and on the Cohesion Fund (2018/0197 COD) should be amended in a way, which does not exclude natural gas technologies from the scope of support granted under ERDF.
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Response to Heavy Duty Vehicles CO2 emission standards

17 Oct 2018

Please find attached the PGNiG position on 'Proposal for a Regulation of the European Parliament and of the Council setting CO2 emission performance standards for new heavy-duty vehicles'.
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Response to Strategy for long-term EU greenhouse gas emissions reductions

10 Aug 2018

Please find attached the PGNiG position on ‘Strategy for long-term EU greenhouse gas emissions reductions’.
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Response to Evaluation of the Directive on safety of offshore oil and gas operations

30 May 2018

In attachment, PGNiG would like to present its comments on Evaluation of the Directive on safety of offshore oil and gas operations.
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Response to Implementing act on a common methodology for alternative fuels unit price comparison

29 Mar 2018

PGNiG position on draft Commission Implementing Regulation on a common methodology for alternative fuels unit price comparison in accordance with Directive 2014/94/EU of the European Parliament and of the Council on the deployment of alternative fuels infrastructure. PGNiG welcomes the possibility to respond to the European Commission proposal for Commission Implementing Regulation on a common methodology for alternative fuels unit price comparison. In our opinion, developing sustainable and low-emission means of transport is a one of the key objectives to achieve ambitious EU climate targets and improve air quality in the EU. In our view, providing customers with objective ‘tool’ for fuels unit price comparison, fits into measures contributing to stimulate the alternative fuels market (including CNG/LNG), which will in turn result in reduction of CO2 and air pollutant emissions. We support efforts to promote alternative fuels, however we would like to share our concerns. We are of the opinion, that providing fuels unit price comparison will emphasize the financial advantage of alternative fuels over conventional ones. However in our view, it should be performed in a way, which minimizes administrative and financial burden imposed on fuel stations owners and information burden imposed on customers. In order to achieve this goal, we propose to establish one ‘statistical passenger car’, which will show the price trend. The fuel consumption to be taken into account for ‘statistical passenger car’, should be calculated on the basis of WLTP (World Harmonized Light Vehicles Test Procedure) results presented in vehicles’ certificates of conformity, as the average value of each type fuel consumption of vehicles registered over i.e. the last quarter prior to the time of calculation. To ensure a transparency, it is crucial to specify the source of the data for fuels price comparison ‘tool’. We point out that to ensure objective and transparent price setting for individual types of fuel and avoid unfair practices, such data should be provided by the respective administration by the Member States. If the fuel prices are expressed only as the average cost for 100 km, the actual cost incurred by customer may differ from the information provided by comparison ‘tool’. Therefore, in order to provide customers with as objective as possible fuels price comparison, we propose to present on each fuel station both: • the average fuel cost for 100 km for ‘statistical passenger car’, calculated on the basis of data in certificates of conformity, as the average value of statistical fuel consumption of vehicles registered over i.e. the last quarter prior to the time of calculation; • the actual fuel cost for 100 km for ‘statistical passenger car’, calculated on the basis of individual fuel stations prices. Alternative fuels such a CNG/LNG are more affordable and more environmental friendly than conventional ones. Increased awareness among consumers will result in greater use of low-emission means of transport.
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Meeting with Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

27 Mar 2017 · current issues

Meeting with Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

2 Dec 2016 · OPAL & NS2

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

12 Oct 2016 · Diversification of gas supply routes including northern corridor

Meeting with Maroš Šefčovič (Vice-President) and

20 Apr 2015 · Gas storage

Meeting with Dominique Ristori (Director-General Energy)

23 Feb 2015 · Oil and gas markets