RAG Companies
RAG
Die RAG Gruppe mit Hauptsitz in Wien ist das größte Energiespeicherunternehmen Österreichs und gehört zu den führenden Speicherbetreibern Europas.
ID: 130261351189-94
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
5 Dec 2025
Thank you for the opportunity to provide input to this consultation. Please find our detailed comments attached. Below we briefly outline the key points that are essential for the development and implementation of underground hydrogen storage, particularly in depleted gas reservoirs: 1) Ensure regulatory neutrality - Taxonomy eligibility must not depend on a RAB: Taxonomy criteria should not depend on inclusion in a regulatory asset base, as future hydrogen regulation under the Gas Market Package will differ between Member States and has not yet been implemented. 2) Allow transitional H2/CH4 blending during early project phases: Early projects will rely on H2/CH4 blending during the market ramp-up; imposing narrower storage-level specifications would hinder timely project development. 3) Sustainability rules must reflect that operators cannot control hydrogen origin: Storage operators cannot influence the production pathway or color of hydrogen entering the grid; sustainability verification must therefore rely on recognized certification schemes. 4) Keep the choice of cushion gas with the operator: Depleted gas reservoirs technically require cushion gas to ensure operational stability. This cushion gas may consist of methane, green H2, low-carbon H2, or gray H2, depending on geological and economic conditions. The choice must remain with the operator and should not affect Taxonomy eligibility. 5) Technical criteria must reflect the role of working gas and cushion gas in porous formations: In depleted gas reservoirs, a part of the injected hydrogen remains as cushion gas due to the physical behavior of porous formations, while the working gas is cycled repeatedly and fully utilized. Technical criteria must therefore take this distinction into account to reflect the actual operational characteristics of depleted gas reservoirs. We kindly refer the Commission to the attached document, which provides the supporting context and technical explanations for the points summarized above. Please do not hesitate to contact us should further clarification be required.
Read full responseResponse to Electrification Action Plan
9 Oct 2025
RAG Austria AG welcomes the opportunity to provide feedback on the Electrification Action Plan (EAP). While the initiative represents an important step towards decarbonization, its current approach places too much emphasis on electrification as the sole pathway. Such a one-dimensional focus risks underestimating the importance of flexibility needs in ensuring security of supply (SoS), and the technical and economic challenges related to grid stability, seasonal balancing and cost efficiency. Security of energy supply must remain a key prerequisite for the EU decarbonization strategy. Electrification will significantly increase overall electricity demand and make the energy system more dependent on variable RES generation, thereby increasing the need for flexibility and reliable backup capacity. Currently, the main backup source relies on flexible electricity imports. The increasing electricity demand reduces import flexibilities since production will be mostly driven by intermittent sources instead of flexible sources. A secure and affordable energy transition therefore requires a diversified energy mix and integrated infrastructure planning across electricity, gas, hydrogen & CO2 systems, esp. including flexible gas-driven power plants. Large-volume H2 storage will be a cornerstone of this integrated approach. By converting renewable electricity into H2, storing it underground and reconverting it into power when needed the Power-to-Hydrogen-to-Power concept Europe can achieve seasonal flexibility that a purely electrified system cannot deliver. This combination of electrolysis, large-volume underground H2 storage and H2-ready power plants allows RES energy to be shifted over weeks or months, bridging gaps between generation and demand. Large-volume storage thus provides a strategic backbone for energy security, system resilience and market stability. Flexible gas-fired power plants are indispensable for stabilizing the power grid and ensuring reliable electricity supply during periods of low RES output. They provide dispatchable capacity that cannot be replaced by weather-dependent generation alone. In the future, H2-ready power plants will take over this role, providing firm generation based on renewable and low-carbon H2. Maintaining and further developing these flexible assets is critical to prevent capacity shortages and safeguard a stable & reliable power system throughout the transition. To support investment in these essential capacities, capacity mechanisms are needed as a core element of the future market design. Energy-only markets fail to adequately value availability, flexibility and reliability, especially in systems dominated by variable RES. Capacity mechanisms should therefore be coordinated at EU level and designed in a technology-neutral and forward-looking way, ensuring that storage and H2-ready generation can participate on equal terms. This approach would provide long-term investment signals and strengthen SoS across all Member States. The EAP should explicitly recognize that SoS is not automatically ensured through electrification alone. Without sufficient dispatchable capacity and large-scale, long-duration storage, the system risks instability and rising costs. The EU path to climate neutrality must rely on a multi-vector energy strategy, integrating electricity, gas, H2 & CO2 infrastructure as complementary building blocks of a resilient, decarbonized energy system. RAG therefore calls on the EU COM to ensure that the EAP explicitly acknowledges the critical role of: Large-volume H2 storage and its timely implementation as a long-term flexibility backbone, Flexible & H2-ready power plants as key instruments for grid stability and secure supply, Capacity mechanisms as market-based tools to safeguard SoS and investment in flexibility. Embedding SoS as a guiding principle across all elements of the EAP is essential to achieve a climate-neutral, cost-efficient, reliable European energy system.
Read full responseResponse to Delegated act on primarily used components under the Net-Zero Industry Act
20 Feb 2025
Thank you for the drafts. We see a need for an inclusion and more detailed description of the following topics: 1) In our opinion, large-scale underground H2 storage should be explicitly mentioned under Energy storage technologies. Components for large-volume H2 storage technologies: a. H2-ready equipment for wells/probes (casing, tubing, cement, wellhead) b. H2-ready plant components required for the injection, separation and transportation of H2 (pipelines, processing, separation, compression, etc.) c. H2 monitoring technologies (sensors, surface monitoring, etc.) d. H2 drying e. Conditioning and separation technologies for hydrogen, gases, solids and liquids 2) The category of hydrogen-ready power plants is still missing. It could be mentioned under other h2 technologies: a. Hydrogen technologies for electricity and heat generation: e.g. hydrogen power plants (CHP) 3) Details on CCS are missing at all: a. CO2-compatible equipment for CO2 wells/probes (casing, tubing, cement, wellhead) b. CO2-compatible plant components required for the injection, capture and transportation of CO2 (pipelines, processing, capture, compression, liquefaction technologies, etc.) c. CO2 monitoring technologies for CCS (sensors, surface monitoring, etc.) d. CO2 drying 4) Under category Energy system-related energy efficiency technologies, pls. include: a. Utilization of process heat and process energy (expanders, etc.) 5) Pls. include under Other H2 technologies, a sub-category of Other H2-Production technologies: a. Pyrolysis/plasmalysis (torches, reactors, suitable catalysts, etc.) b. Conditioning and separation technologies for hydrogen, gases, solids and liquids 6) Pls. include under CO2 utilization technologies: a. plants for splitting and synthesis for the utilization of CO2 (e.g. methanation) 7) Pls. include under carbon storage technologies: a. Components for carbon enhancement, processing and utilization of the valuable raw-material solid carbon. Thank you for considering our input!
Read full responseResponse to Greenhouse gas emissions savings methodology for low-carbon fuels
24 Oct 2024
RAG Austria AG welcomes the opportunity to comment on the topic of specifying low-carbon fuels. As far as the draft delegated act is concerned, we see a need for clarification and improvement on the following topics: 1) Reduction of minimum savings threshold from 70% to 40% necessary To create a level-playing field for low-carbon technologies and given that some technologies are still in the process of scaling up their technology readiness levels, there is a clear necessity to introduce an initial savings threshold of 40% which can subsequently be increased to 70% in 2030 or later. 2) More clarity in terms of evaluating pyrolysis and solid carbon needed Provisions in A.12/A.17/A.18 tend to contradict each other which makes it challenging to assess the suitability for a low-carbon hydrogen production pathway via the pyrolysis process Since pyrolysis does not generate any direct atmospheric emissions, it is necessary to not work with default values for natural gas upstream emissions but use project specific local values To achieve a more accurate and fair assessments of CO2 emissions for low-carbon technologies as well as encouraging the use of renewable energy sources and more localized energy production, the following changes need to be implemented into the low-carbon fuels delegated act: o Separate Gas CO2 Footprint for Member States: Each member state should have its own CO2 footprint for gas, similar to how electricity values are calculated. Using a single value that includes a high transport footprint is not objective and does not accurately reflect the emissions of each state. o Regional Electricity Mixes: Regional (and not only national) electricity mixes should be taken into account. If a region uses 100% certified renewable energy, it should have a CO2 factor of zero. This principle should also apply to Power Purchase Agreements (PPAs). 3) Regulatory uncertainty for low-carbon fuels producers due to DAs references to upcoming legislation - Currently there is no grandfathering rule foreseen, i.e., no grandfathering of the current regulation for plants built under existing rules, which means that new rules must be applied whenever implemented. 4) The arbitrary setting of CO2eq emissions from methane for the entire EU, including the 40% increase for imported gas, needs to be avoided Project-specific values for locally produced electricity and natural gas (if certified) need to be considered. A clear statement in the delegated act is needed that project specific gas with individual emission values can be used for certification of GHG emissions for elastic inputs Hence deviation from Annex B values should be possible (if demonstrably better CO2eq values can be set for specific projects) CO2 certification schemes and bodies need to be available to give local producers and importers the chance to provide specific values 5) Misleading terminology usage in DA (CO2 and carbon terms are often mixed up): However, in the context of this delegated act, a proper usage of terms (differentiating between CO2, CO2eq and carbon) is especially important since the process of pyrolysis will create both hydrogen and solid carbon. 6) Delegated Act (pls. See 6 [recital]) picks up core topics of CCS Directive that should not be part of the Delegated Act Delegated act should not assess topics that are governed in other legislative acts The CCS directive is the only legislative act that presents requirements for geological storage and respective storage sites This delegated act has to be in line with the terms and definitions of the CCS Directive. Please see the attachment for more extensive feedback. Thank you for considering our input.
Read full responseResponse to Permanent storage of EU ETS emissions through carbon capture and utilisation
16 Jul 2024
1) The Delegated Act on permanent CCU should encompass any source of carbon, once it can be managed in a sustainable way. Hence, an important innovation in the CCUS sector is methane electrolysis/plasmalysis/pyrolysis, which uses natural gas to produce climate-neutral hydrogen and solid carbon without CO2 emissions. The solid carbon (C) produced can be added to the soil in agriculture, for example, to improve soil quality and is hence permanently bound. In industry, the raw material C is used in the construction industry or for the production of batteries, computer chips and carbon fibers, etc. 2) In general, we see the definition of permanently bound CO2 (see Art. 3 (4)) as highly problematic: - The interpretation that it is only a permanent binding if it takes place for a period of at least several centuries is not acceptable and actually worsens the starting position for CO2 reduction measures that are already technically possible, because this proof will fail in many processes. - Hence, in terms of a rapid reduction of the CO2 concentration in the atmosphere, it would be more appropriate and necessary to describe even shorter periods of time, e.g. 30 years, as permanent, provided that utilization in terms of CCU is possible at the end of this period. - Even processes that cycle CO2 permanently should be suitable for at least freezing the CO2 status - e.g. methanation of CO2. This would already make CO2 savings possible and the state of the art could develop accordingly. In combination with technology-open research and development, this could create a broader basis for rapid applications. - We are therefore of the opinion that an immediate and practicable implementation of CO2 savings is better than over-regulated and far future (and therefore not really predictable) requirements that severely restrict innovation and inventiveness. - In addition, permanent or at least for several centuries is a term that cannot be precisely defined and will lead to difficulties of interpretation from the outset. - Overall, we welcome the statement in the preliminary remark (4) that the geological storage of CO2 is obviously a benchmark from the EU's point of view and must therefore be permissible. 3) The possibility of CO2 savings through circular economies should be more strongly recognized in the current draft. This can be done by recognizing the potential for closed CO2 cycles that involve cooperation between several companies and locations (sector coupling).
Read full responseMeeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson)
3 Oct 2023 · Exchange with RAG Austria on hydrogen storage