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Snam S.p.A.

Snam

Snam is a leading European operator in natural gas transport, storage, and regasification.

Lobbying Activity

Meeting with Alessandra Moretti (Member of the European Parliament)

13 Jan 2026 · Meeting temi ENVI

Snam Urges Broader Gas Infrastructure Inclusion in EU Taxonomy

3 Dec 2025
Topic — The Commission is reviewing technical screening criteria for the EU Taxonomy environmental acts.
Message — Snam recommends biomethane production qualifies as sustainable regardless of end use. They also call for regasification and hydrogen projects to be eligible.12
Why — This would reduce financing costs and support the repurposing of existing infrastructure.3
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Meeting with Carlo Fidanza (Member of the European Parliament)

3 Dec 2025 · legislative update

Energy giant Snam seeks dedicated funding for gas infrastructure

11 Nov 2025
Topic — EU's next long-term budget and competitiveness funding priorities post-2027.
Message — Snam requests increased predictable funding for energy infrastructure and separate funding streams for electricity and gas molecules. They want geographically targeted funding along priority corridors and coordination across EU funds to support the entire energy value chain.123
Why — This would secure EU funding for their gas pipeline network and hydrogen infrastructure investments.45
Impact — Renewable electricity projects lose if molecules funding diverts resources from electrification priorities.6
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Snam urges EU strategic gas reserve and stronger infrastructure standards

13 Oct 2025
Topic — EU revision of energy security framework for decarbonized, integrated system.
Message — Snam requests updated security standards considering supply availability not just capacity, harmonized supply standards including long-term contracts, and establishment of a European strategic gas reserve. They advocate maintaining molecules in the energy mix to support renewable integration and system flexibility.123
Why — This would secure their gas infrastructure role and storage business in the energy transition.45
Impact — Climate advocates lose stronger push toward electrification and away from fossil gas infrastructure.67
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Snam Urges Technology Neutrality and Multi-Molecule Integration

9 Oct 2025
Topic — The consultation aims to address barriers and promote electrification of energy demand.
Message — Snam calls for a technology-neutral approach that integrates "electrons and molecules" as complementary elements. They recommend promoting hydrogen production through specific targets and key performance indicators.12
Why — Repurposing existing gas infrastructure for hydrogen and CO2 reduces the risk of stranded assets.34
Impact — Strategic industries and households face unviable costs if electrification is pursued without alternatives.56
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Snam Advocates for Gas Use in EU Heating Strategy

8 Oct 2025
Topic — A strategy to accelerate the transition to renewable energy for industrial and residential heating.
Message — Snam advocates for a technology-neutral approach that recognizes the role of biomethane and hydrogen. They propose using existing infrastructure and hybrid solutions to ensure a cost-effective transition.12
Why — This approach would allow Snam to avoid the obsolescence of its massive gas infrastructure.3
Impact — Residents of historical buildings could suffer under strict rules requiring expensive, impractical renovations.4
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Snam urges EU to unlock infrastructure aid for green investments

6 Oct 2025
Topic — EU regulation governing when state aid is allowed without prior Commission approval.
Message — Snam requests higher aid thresholds for infrastructure projects, broader definitions including CO2 storage, and flexible hydrogen rules. They argue current limits and rigid categories prevent large-scale decarbonization investments from receiving timely support.123
Why — This would accelerate funding for their large-scale hydrogen and carbon capture projects.45
Impact — Smaller renewable energy projects lose if aid shifts toward large infrastructure operators.
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Meeting with Carlo Fidanza (Member of the European Parliament)

24 Sept 2025 · legislative updates

Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy)

24 Sept 2025 · REPowerEU, CCUS

Snam calls for simplified CO2 transport certification rules

22 Sept 2025
Topic — EU certification framework for permanent carbon removal activities including DACCS and BioCCS.
Message — The company requests that CO2 network operators define transport segments and calculate emissions values centrally, rather than requiring individual projects to coordinate. They seek clear objective criteria instead of vague cost-based rules, and standardized emission factors for transport components.123
Why — This would reduce administrative burden and coordination requirements for their Ravenna CCS hub and CO2Vault infrastructure projects.45
Impact — Environmental integrity suffers if standardized factors replace site-specific measurement of actual emissions.67
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Snam urges regulated business models for CO2 transport infrastructure

11 Sept 2025
Topic — EU initiative to create competitive markets and transportation infrastructure for carbon dioxide.
Message — Snam proposes a regulated framework using the Regulatory Asset Base model for infrastructure access. They request full cost coverage and protection from risks like underutilized pipelines.12
Why — This framework guarantees stable capital returns and protects Snam from infrastructure underutilization.34
Impact — Member States or taxpayers bear financial risks if industrial demand for transportation fails.5
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Snam urges EU to include hydrogen and CO2 in grids package

1 Aug 2025
Topic — EU proposal to upgrade and expand European electricity and hydrogen grid infrastructure.
Message — Snam requests that the EU Grids Package clearly include hydrogen and carbon capture infrastructure alongside electricity. They want increased public funding, de-risking mechanisms like guarantees and contracts, and simplified permitting procedures for cross-border projects.1234
Why — This would secure public funding and regulatory protection for Snam's hydrogen and CO2 infrastructure investments.567
Impact — Electricity grid operators lose relative priority as resources shift toward hydrogen and CO2 infrastructure.8
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Snam calls for technology-neutral ETS reforms supporting hydrogen infrastructure

8 Jul 2025
Topic — Review of EU Emissions Trading System design and Market Stability Reserve mechanisms.
Message — Snam requests fair competition rules between electrolytic and fossil hydrogen, expanded emissions accounting for low-carbon hydrogen in gas grids, and technology-neutral Innovation Fund design. They advocate for contracts for differences to support industrial decarbonization and geographically balanced auction mechanisms.1234
Why — This would level the playing field for their renewable hydrogen infrastructure investments against fossil competitors.56
Impact — Wealthier member states lose competitive advantage as geographically balanced funding reduces their disproportionate access to resources.78
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Snam calls for increased funding and geographic quotas for hydrogen

8 Jul 2025
Topic — The European Commission is evaluating the performance and design of the Innovation Fund.
Message — Snam proposes introducing Contracts for Difference and increasing aid intensity above sixty percent. They also suggest geographic funding pots to support cross-border hydrogen infrastructure.123
Why — The company would benefit from greater financial certainty and higher subsidies for its infrastructure.45
Impact — The most competitive project developers may lose funding if resources are ring-fenced by geography.6
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Snam Urges Faster Permitting for Hydrogen and CO2 Infrastructure

30 Jun 2025
Topic — The consultation focuses on accelerating industrial decarbonisation through faster permitting and infrastructure investment.
Message — Snam calls for streamlined permitting procedures that coordinate industrial installations with their associated infrastructure. They also advocate for including low-carbon hydrogen and carbon capture as priority technologies for fast-track approvals.12
Why — Coordinated permitting and financial guarantees would reduce investment risks for Snam’s infrastructure projects.34
Impact — Pure renewable energy proponents lose if gas-derived technologies receive the same support.5
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Meeting with Joachim Balke (Head of Unit Energy)

19 Jun 2025 · Exchange of views on the results of the evaluation of SNAM's hydrogen PCI and PMI candidate projects

Meeting with Marco La Marca (Cabinet of Commissioner Dubravka Šuica), Tena Misetic (Cabinet of Commissioner Dubravka Šuica)

4 Jun 2025 · Energy cooperation with the Southern Neighbourhood

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

4 Jun 2025 · Discussion on the role of CCS in accelerating decarbonisation

Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen), Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen)

26 May 2025 · Energy Infrastructure

Meeting with Eva Schultz (Cabinet of Executive Vice-President Roxana Mînzatu), Vanessa Debiais-Sainton (Cabinet of Executive Vice-President Roxana Mînzatu)

1 Apr 2025 · Presentation of Strategic Plan 2025-2029

Gas operator Snam backs simpler EU taxonomy reporting rules

26 Mar 2025
Topic — This initiative seeks to simplify sustainability reporting by making certain requirements more flexible.
Message — Snam supports reducing administrative burdens by introducing materiality thresholds and simpler environmental criteria. They suggest self-certifications for low-risk activities and making secondary objective reporting voluntary.123
Why — The group would reduce high expenses for human resources and software.4
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Meeting with Cristina Lobillo Borrero (Director Energy)

26 Mar 2025 · Trans-Adriatic Pipeline, Southern Gas Corridor

Meeting with Jozef Síkela (Commissioner) and

24 Mar 2025 · Global Gateway

Meeting with Lukasz Kolinski (Director Energy)

6 Mar 2025 · Overview of Snam’s updated industrial plan

Meeting with Joachim Balke (Head of Unit Energy)

4 Mar 2025 · Exchange on the state of play of SNAM's Projects of Common Interest, namely Italian Hydrogen Backbone and Callisto

Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

SNAM welcomes the opportunity to provide feedback on the draft Implementing regulation specifying the pre-qualification and award criteria for auctions in the deployment of renewable energy in relation to Article 26 of Regulation (EU) 2024/1735. Snam is Europes leading operator in energy infrastructure promoting the energy transition through a multi-molecule energy system catering for decarbonization, competitiveness and reliability thanks to the contribution of biomethane and hydrogen. General Comment The EUs Competitiveness Compass, informed by the Draghi Report, outlines a strategic framework to enhance Europes economic resilience and global competitiveness while advancing decarbonization. A key focus is balancing regulatory requirements with simplifying administrative processes to foster business innovation and growth without excessive regulatory burden. Modernizing energy infrastructure is essential for the EUs decarbonization goals, with the European Commission estimating nearly 170 billion needed for hydrogen infrastructure alone between 2024 and 2040 in their report titled Investment needs of European energy infrastructure to enable a decarbonised economy. Interconnected and flexible energy systems are critical to reducing these costs as indicated in the EU Energy System Integration Strategy. In this context, we recognise the importance of the Net-Zero Industry Act (NZIA) in enabling appropriate regulatory balance and energy system integration, and we have included below detailed comments on how non-price criteria in renewable energy auctions can support these objectives. Sustainability contribution: Energy system integration criterion (Article 15) The assessment of the sustainability contribution by means of energy system integration criteria should include the broader energy system beyond electricity. The current wording however is solely focused on integrating renewable energy sources (RES) into the electricity systems without mention of other energy systems. For a full respondence to the objectives of the EU Energy System Integration, the scope should be broadened to encompass all integrated energy systems, from electricity to hydrogen, renewable and natural gas. Network related functions and decarbonisation speed should be considered in the assessment The concepts of network-related functions and whole system cost reduction should be introduced to ensure a whole-of-system approach to the assessment. Network-related functions refer to the characteristics of specific RES in lowering system costs by reducing network congestion and balancing costs across different networks. A metric should also be included to assess projects against their ability to decarbonise the energy system The proposed assessment should not be limited to awarding hydrogen projects with direct connection to RE production facilities The current wording of article 15(4) seems to encompass only RFNBOs produced via direct electricity connections, while indirect connections through PPAs should also be explicitly considered. Environmental Sustainability carbon footprint (Article 8) In light of the already comprehensive sustainability standards and certification processes required by the Renewable Energy Directive (RED), the requirement of exceeding the minimum legal requirements when setting criteria for the environmental sustainability of projects by Member States (as stated in Article 26(2) of Regulation (EU) 2024/1735) would result in an unnecessary burden. This could be addressed by explicitly excluding the applicability of this requirement for biogas and biomethane in the Environmental sustainability carbon footprint criterion.
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Meeting with Elena Donazzan (Member of the European Parliament)

30 Jan 2025 · Situazione dell mercato del Gas in Europa

Snam Urges Exclusion of Low-Carbon Fuels from Database Reporting

7 Nov 2024
Topic — Regulation to expand Union database tracking to the point of raw material production.
Message — Snam requests excluding low-carbon fuels from the scope of new reporting requirements. They also propose a simplified certification for raw materials delivered directly to production plants.12
Why — The company would avoid duplicate reporting requirements and reduce administrative compliance costs.34
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Snam calls for fair competition and low-carbon hydrogen transition

25 Oct 2024
Topic — This consultation defines the methodology for calculating greenhouse gas emission savings from low-carbon fuels.
Message — Snam requests a transitional phase for low-carbon hydrogen to match renewable hydrogen rules. They advocate for specific emission values for gas and removing the 40% methane increase.123
Why — These changes would lower compliance burdens and protect Snam's significant gas infrastructure investments.45
Impact — Renewable electricity-based hydrogen producers lose their current regulatory advantage over fossil-derived alternatives.6
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Meeting with Stefano Cavedagna (Member of the European Parliament) and L'Oréal

9 Oct 2024 · Introductory meeting

Response to Interim evaluation of the Connecting Europe Facility 2021-2027

24 Sept 2024

SNAM welcomes the opportunity to provide feedback on the interim evaluation of the CEF 2021-27. With a view to support potential refinements in the design of future allocation rounds, we provide feedback reflecting our experience gained throughout the submission of project proposals within CEF2 and our thinking relating the future of gas infrastructure. -Need for a tailored approach to EU H2 infrastructure within CEF-Energy A first consideration is related to the effectiveness of CEF2 in contributing to the creation of trans-EU decarbonised gas networks, both in terms of avoiding infrastructure bottlenecks, contributing to energy markets integration, and of providing a level of funding suitable to the challenges facing gas markets. As for the latter, we note that the 5.84 bn budget under CEF-Energy 2021-27 seems inconsistent with the challenges associated with the ramp up phase of developing trans-EU H2 infrastructure. Notably, the investment need underlying the development of the European H2 Backbone (EHB) is estimated at 80-143 bn. In this sense we fully endorse the Draghi report recommendation to reinforce the EU instrument dedicated to financing interconnectors. Consistently, we share some concern regarding the fact that while the last TEN-E revision expanded its scope to new and updated energy infrastructure categories, the budgetary allocation of CEF2 energy remained unchanged with respect to previous allocations. The increase in CEF2 budgetary allocation for the updated TEN-E categories is even more necessary as they refer to industrial sectors in the start-up phase, namely H2 and CO2 infrastructures. Additionally, regarding the effectiveness of CEF2 in contributing to EU energy markets integration by mitigating (H2) infrastructure bottlenecks, we believe that broader considerations should be made in relation to how the support provided by CEF reconciles with the design of the EU H2 Bank. The first auction of the EU H2 Bank awarded 720 million to seven projects, with 87% of capacity located across Corridor B of the EHB. As we noted in our response to the EU H2 Bank consultation, the cost reduction drivers that yielded this outcome arguably apply only to projects within a subset of EU countries (eg. projects that can access cheap and abundant wind/solar altogether). In this sense, we concluded that it seemed likely that, if no specific design measures were taken, the next rounds of the H2 Bank auctions would yield similar outcomes. As a potential solution, we suggested that an immediate measure that the EC could take to ensure that H2 markets deploy homogeneously across the whole EEA is to create five separate allocation pots, promoting production across the five EHB Corridors. In relation to CEF, an alternative solution could be to reflect within CEF allocations, the outcomes of the EU H2 Bank auctions in a way to avoid that none of the 5 EHB Corridor is left behind across the two funding programmes as a whole. Another point we will like to underline is the need for CEF Transport strengthening: In relation to the CEF Transport for Alternative Fuels Infrastructure Facility (CEF-T AFIF), we also believe that there is some merit in strengthening the provision concerning aid intensity in a way that cross border decarbonized gas infrastructure business model becomes economically sustainable. Specific suggestions in this relation would be: 1. For H2 refueling infrastructures, increasing aid intensity to 70-80% of eligible costs; 2. Reinstating LNG refueling infrastructures within the CEF, providing for 20-30% aid intensity; 3. As applied to the AFIF program in particular: i) Allow the eligibility of the costs associated with buildings and works associated, as well as the costs associated with relevant authorizations; ii) Allow expenses relating to synergistic elements (eg. energy storage plants and green H2 production plants serving the transport sector) above the existing 20% limit currently applying.
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Snam urges zero-emission recognition for hydrogen and synthetic fuels

29 Jul 2024
Topic — This consultation updates rules for monitoring and reporting greenhouse gas emissions under the EU ETS.
Message — Snam requests a zero-emission factor for hydrogen regardless of its production method or origin. They propose using purchase records to determine hydrogen fractions in gas blends and suggest aligning grid definitions with interconnected infrastructure concepts.123
Why — These changes would reduce carbon costs and facilitate hydrogen transport in existing gas grids.45
Impact — Environmental groups lose the ability to penalize high-carbon hydrogen production methods.6
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Snam urges more flexible EU carbon capture storage rules

16 Jul 2024
Topic — Establishing conditions for greenhouse gases to be considered permanently chemically bound in products.
Message — Snam argues the approach is too restrictive and should include recyclable products like plastics. They also suggest adding specific chemical products to the list of permanent storage solutions.12
Why — Broader rules would allow Snam to provide carbon services to more industrial sectors.3
Impact — Climate groups may fear that including recyclable products increases the risk of carbon re-emission.4
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Meeting with Fabrizio Balassone (Cabinet of Commissioner Paolo Gentiloni)

17 Apr 2024 · Status of the implementation of SouthH2Corridor project in collaboration with Algeria, Tunisia, Austria and Germany

Meeting with Nicolas Schmit (Commissioner) and

6 Mar 2024 · Labour and skills shortages, the EU's social targets, the European Pillar of Social Rights Action Plan

Response to Mid-term evaluation of the ERDF, the CF and the JTF 2021-2027

9 Oct 2023

Snam welcomes the opportunity to provide feedback on the European Regional Development Fund, Cohesion Fund and Just Transition Fund for 2021- 2027 mid-term evaluation. We recall the significant role of renewable and low carbon hydrogen for the energy transition as outlined in the FF55 as well as in the REPower EU, including hydrogen targets to 2030. As applied to the underlying funding gap, encompassing all parts of the value chain, while a dedicated EU funding mechanism has been created to kick off hydrogen production the so called Hydrogen Bank the EU support to hydrogen infrastructure remains insufficient. In this sense, a transfer of budget from the cohesion fund to increase CEF energy, consistently with what happens for CEF transport, would be apposite and functional to delivering the broader EU energy and climate objectives of accelerating the phase out of Russian fossil fuels while promoting environmental objectives. In turn, we also suggest that a future revision of the Cohesion Fund takes into account the decarbonization objectives of the EU and in particular the REPower EU targets.
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Snam calls for harmonized EU rules for CO2 infrastructure

31 Aug 2023
Topic — EU initiative to develop infrastructure for industrial carbon management and storage.
Message — Snam proposes a harmonized EU regulatory framework for CO2 transport. They advocate for an EU CCUS bank to provide infrastructure funding. They suggest making storage obligations for oil and gas producers indicative.123
Why — Harmonized rules and subsidies would provide the investment predictability Snam requires.4
Impact — Environmental groups lose out if mandatory storage requirements for producers become voluntary.5
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Snam Urges Consistent Emission Factors and Engine-Specific Methane Reporting

30 Aug 2023
Topic — This consultation establishes rules for monitoring and reporting greenhouse gas emissions from shipping.
Message — The organization recommends aligning global warming potential factors with the Renewable Energy Directive for consistency. They suggest reassessing methane slippage default values based on specific engine types. For high-pressure engines, they propose removing methane slip from certain calculation formulas.123
Why — This alignment would reduce reporting complexity and better reflect their engine technology's performance.45
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Snam advocates for zero-emission status for all hydrogen and synthetic fuels

23 Aug 2023
Topic — The European Commission is updating rules for monitoring and reporting greenhouse gas emissions.
Message — Snam suggests hydrogen fuel should receive a zero-emission rating regardless of its origin. They request using purchase records to track renewable fuels within the gas grid. Furthermore, carbon removal credits should be allowed for compliance with emissions regulations.123
Why — Snam would reduce compliance costs and create new revenue for its gas network.45
Impact — Environmental groups may lose if high-carbon hydrogen is treated as having zero emissions.6
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

3 Jul 2023 · South H2 Corridor, REPower EU priority corridors for the import of green hydrogen from north Africa

Meeting with Fabrizio Balassone (Cabinet of Commissioner Paolo Gentiloni)

28 Jun 2023 · Projects on hydrogen pipelines and gas solutions between Africa and Europe.

Snam advocates for renewable fuel recognition in truck standards

19 May 2023
Topic — The Commission is reviewing CO2 emission standards for new heavy-duty vehicles.
Message — Snam requests a Carbon Correction Factor to recognize the decarbonization potential of sustainable fuels. They want the legislation to include a definition of CO2 neutral fuels that covers biofuels and biogas. This approach aims to support domestic value chains and technologies beyond simple electrification.123
Why — This would protect Snam's significant financial investments in its existing gas refueling infrastructure.45
Impact — Electric vehicle manufacturers lose their status as the sole recognized zero-emission technology pathway.6
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Snam urges taxonomy update to include carbon-neutral fuels

3 May 2023
Topic — Defining sustainable economic activities for water, circular economy, pollution, and biodiversity objectives.
Message — Snam requests updating vehicle emission references to reflect new laws and synthetic fuel inclusion. They suggest criteria should align with expected revisions opening to carbon-neutral fuels.1
Why — This allows Snam to maintain market position by labeling gas transport as green.2
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Snam Urges EU Taxonomy to Recognize Carbon Neutral Fuels

3 May 2023
Topic — Establishing criteria for sustainable investments contributing to European environmental policy objectives.
Message — Snam recommends replacing zero tailpipe emission requirements with life-cycle emission standards. They argue for the inclusion of carbon neutral fuels and infrastructure for zero-emission bunkering. The organization seeks a consistent accounting approach that treats biofuels as zero-emission sources.123
Why — This would allow more of Snam's gas-related infrastructure and fuel investments to qualify as sustainable.45
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Meeting with Mario Nava (Director-General Structural Reform Support)

30 Mar 2023 · Exchange of views on energy matters.

Meeting with Maroš Šefčovič (Executive Vice-President) and

30 Mar 2023 · ENERGY

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson)

30 Mar 2023 · Gas markets package - progress on storage refilling in Italy - progress of REPowerEU-relevant infrastructure projects

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

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

Meeting with Maroš Šefčovič (Executive Vice-President) and

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

Meeting with Seán Kelly (Member of the European Parliament) and EUROGAS and Uniper

13 Dec 2022 · Dinner Debate: Hydrogen and Decarbonized Gas Markets Package: an MEPs – Industry Conversation

Meeting with Nicola Danti (Member of the European Parliament)

12 Oct 2022 · Gas Package

Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur)

28 Sept 2022 · Meeting on gas and hydrogen regulation

Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

27 Sept 2022 · Gasmarktrichtlinie

Meeting with Silvia Sardone (Member of the European Parliament, Rapporteur)

31 Aug 2022 · Meeting on Methane Regulation

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

8 Jul 2022 · Discussion about diversification of supplies, infrastructure and hydrogen.

Snam Urges More Flexible Rules for Renewable Hydrogen Classification

17 Jun 2022
Topic — The consultation defines rules for classifying hydrogen as renewable and calculating greenhouse gas savings.
Message — Snam suggests delaying the matching of hourly electricity production and consumption until 2035. They also propose lowering the renewable electricity threshold for local market regions. Finally, they advocate for extending the transition period for new projects until 2030.123
Why — Relaxing these requirements would significantly lower production costs and enable continuous fuel supply.45
Impact — Environmental advocates lose as these changes allow hydrogen to be labeled renewable despite higher emissions.6
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

20 May 2022 · Introductory meeting with new Snam CEO

Snam urges proportional and flexible methane emission reporting rules

14 Apr 2022
Topic — The Commission is proposing new rules to monitor and reduce methane emissions.
Message — Snam recommends a proportional approach that avoids high-cost measures with little environmental benefit. They suggest aligning reporting with existing industry standards and allowing flexible leak detection schedules.12
Why — These proposals would lower compliance costs and ensure financial compensation for infrastructure investments.34
Impact — Environmental groups lose out as delayed quantification and flexible inspections may slow emission reductions.56
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Snam urges flexible hydrogen financing and delayed oversight body

12 Apr 2022
Topic — This consultation updates EU gas market rules to support renewable and low-carbon hydrogen.
Message — Snam requests early low-carbon hydrogen standards and flexible infrastructure financing. They also propose delaying a separate hydrogen network body's full operation until 2030.12
Why — Utilizing existing gas revenue for hydrogen infrastructure reduces Snam's financial and regulatory risks.3
Impact — Consumers and taxpayers may face higher costs if stranded asset risks shift to them.4
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Snam advocates for flexible hydrogen unbundling and blending rules

12 Apr 2022
Topic — Legislative revision to adapt EU gas markets for renewable and low-carbon hydrogen integration.
Message — Snam requests maintaining the 5% hydrogen blending threshold and setting standards for low-carbon hydrogen immediately. They advocate for flexible infrastructure financing and delaying a separate hydrogen network body until 2030.123
Why — These measures would protect Snam's infrastructure investments and prevent regulatory discrimination against its corporate structure.45
Impact — Energy-intensive industries or gas consumers may bear costs through cross-subsidies allowed during the transition.67
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

8 Apr 2022 · Discussion about EU preparedness on gas storage, energy prices and prospects of EU-US energy cooperation.

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

Snam welcomes the opportunity to provide feedback on EC initiative on the revision of the Energy Performance of Buildings Directive, setting the very ambitious goal of decarbonising the EU's building stock by 2050. We share the ultimate objective of the revision, and welcome a number of aspects in the proposal such as the endorsement of the Life Cycle Approach for the calculation of the Global Warming Potential of future buildings, the introduction of MEPS (including on public buildings) and the extensive financial tools supporting the proposal (RRF/MFF/SCF). SNAM wishes to highlight some important aspects that we believe will be important in order to ensure that final legislation is fit for purpose: • In relation to the role of renewable energy taken from the grid: Based on the current proposal only renewable energy that is locally produced would be compliant with art. 2 and other related provisions, incl. art 7 and 9. In particular, art. 2/annex III define ZEB as building(s) with a very high energy performance, where the residual energy still required is fully covered by energy from renewable sources generated on-site and that (ZEB) shall not cause any on-site carbon emissions from fossil fuels. In turn, NZEB are defined as buildings where the residual energy is mainly covered by energy from renewable sources, including energy from renewable sources produced on-site or nearby. Grid connection is currently the main way to supply most buildings with energy. In light of this as well as of the cost efficiency associated with the use of existing infrastructure, we believe that the Directive should be amended to allow extending the scope of the “zero-emission building” and “nearly zero-Emission” building to renewables energy sourced from the grid and certified through Guarantees of Origin and long-term Renewable Energy Purchase Agreements. It is key that the legislation is framed in a way that promotes locally sourced energy without penalizing renewable energy sourced also from the grid. • In relation to the contribution of hybrid heat pumps and the role of renewable and low carbon gases: The legislation should be more ambitious in taking full account of the potential of renewable and low carbon gases in decarbonizing the existing and future building stock. The more so, in light of the increased ambition in terms of accelerating the shift from fossil gas to renewables as set out in the REPowerEU Communication, including a new target @2030 for biomethane (production of 35 bcm) and for hydrogen (21 M tons). In this sense, the legislation should allow for renewable gases such as hydrogen and biomethane to contribute to heat decarbonisation in buildings also via innovative technologies such as fuel cells (FCs) and hybrid heat pumps. In these hybrid systems, the hydrogen boiler would help to meet peak demands during very cold winter days. Also technologies based on gas and hydrogen such as absorption heat pumps could give a significant contribution to the decarbonization of the building sector, especially in those cases where a deep renovation is technically not feasible or economically not justifiable as it may frequently happens for buildings located in historic centers. Moreover, in the short term, blending should be considered as a viable decarbonisation option with limited costs for consumers. The extensive gas grid in place could be partially repurposed for the wide-scale deployment of hydrogen. The current proposal of Directive suggests that there should be no financial incentives for the installation of boilers powered by fossil fuels as of 2027 and suggests obligation to include in the National Building renovation plan a roadmap for phasing out of fossils fuel in H&C by 2040. We believe that replacement targets for a progressive increase of renewable and low carbon gases would be more effective, as they would maintain a broader set of affordable choices for households in a technology neutral way.
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and Eni S.p.A.

16 Mar 2022 · Discussion on REPowerEU, biogas, gas storage, outreach to neighbourhood

Response to Count your transport emissions: CountEmissions EU

17 Dec 2021

SNAM welcomes this initiative to set a common methodology to calculate and monitor GHG emissions of transport and logistics. The standard EN 16258 "Methodology for calculation and declaration of energy consumption and greenhouse gas emissions of transport services" provides a standard which, although it is considered insufficiently precise, can be used by freight forwarders in a targeted approach. We support a Life-Cycle Approach, which is the most comprehensive way of assessing environmental impacts of products and services and to properly value the benefit of biofuels. However, harmonization with the guidelines ISO 14040-14044 (ISO 14040:2006 Environmental management — Life cycle assessment — Principles and framework; ISO 14044:2006 Environmental management — Life cycle assessment — Requirements and guidelines) , which provide the comprehensive methodology to calculate life-cycle emissions from cradle to grave, is needed. The assumptions of the calculation methodology should be comprehensive and follow the technology-neutral principle. LCA, from cradle to grave, provides transparent and complete information and allows to accurately evaluate and compare vehicles contributions to decarbonization. Moreover, LCA emissions quantification methodology, already implemented by RED II and proposed FuelEU Maritime, should be pursued by other EU legislative acts (e.g. the whole Fit for 55 package). Finally, LCA is particularly relevant to correctly value the decarbonization value of biogas and biomethane, which can have even a negative GHG impacts depending on the feedstocks (e.g. manure) used for their production.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

SNAM welcomes the opportunity to provide input on this proposal. Please find attached our detailed feedback on the Fit for 55 package, with a focus on the revision of the Energy Efficiency Directive (EED).
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Response to Revision of the Energy Tax Directive

18 Nov 2021

SNAM welcomes the opportunity to provide input on this proposal. Please find enclosed our detailed feedback.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

SNAM welcomes the opportunity to provide input on this proposal for a Regulation. Please find attached our detailed feedback.
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

SNAM welcomes the opportunity to provide input on this proposal for a Regulation on the deployment of alternative fuels infrastructure (AFIR); please find attached our detailed feedback.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

SNAM welcomes the opportunity to provide input on the revision of the EU renewable energy rules; please find attached our detailed feedback.
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Meeting with Paolo Gentiloni (Commissioner)

17 Nov 2021 · Short courtesy meeting with exchange of views on green economy and new challanges in Covid times

Meeting with Kadri Simson (Commissioner) and

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

Response to FuelEU Maritime

8 Nov 2021

SNAM welcomes the opportunity to provide input on this proposal for a Regulation; please find attached our detailed feedback.
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Snam urges EU to recognize gas certificates in carbon market

8 Nov 2021
Topic — A consultation on revising the carbon trading system to reach higher climate goals.
Message — Snam wants the EU to recognize gas certificates in carbon trading for emission offsets. They also advocate for measuring vehicle emissions based on full lifecycles instead of tailpipes.12
Why — This would stimulate investment in gas infrastructure and lower operational compliance costs.3
Impact — Proponents of pure electric transport would face competition from gas-powered vehicle technologies.4
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

Please find SNAM's feedback in the attached document.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

6 Oct 2021 · European Green Deal, sustainable finance

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

6 Jul 2021 · SNAM would like to exchange on the work on the IPCEI.

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

31 May 2021

SNAM welcomes the recent introduction of the ‘Taxonomy’ and the recent proposals of Delegated Acts aimed at promoting sustainable investment. We therefore welcome the opportunity to respond to this consultation. Considering the importance of the innovation introduced by this Reg. and that companies will face more complexity and the need to adapt their reporting systems, a phased implementation of these Del. Acts is necessary. It is also fundamental to ensure flexibility in the reporting to consider the specificity of each sector. IMPROVEMENT AREAS a. Reducing the KPI reporting period in art. 9.3 to 3 years instead of 5, in line with the best practices for financial and sustainability reporting, and with no retroactivity for the KPI disclosure. b. Concerning the Capex plan (1.1.2.2) the limitation to a 5-year period is too restrictive and does not correspond to the lifetime of certain infrastructural investments. We would suggest amending as follows: “The CapEx plan mentioned under point (a) and point (b) can exceed five years where a longer period is objectively justified by specific features of the economic activity and the upgrade concerned”. The notion of “expansion” should also include the maintenance activities, when functional to the expansion of aligned activities. c. In the turnover KPI (1.1.1), with regard to the proportion of turnover linked to activities Taxonomy-aligned, it is worth noting that the current provisions might be cumbersome for undertakings whose activities are regulated, as the Regulated Asset Base would have to be split for each single asset linked to Taxonomy-aligned activities (in a retroactive way). For this reason a degree of flexibility in the definition of this KPI should be foreseen. CLARIFICATION AREAS 1. The provisions in recital 13 (application of this Del. Act in 2022) should be clarified regarding the qualitative reporting mentioned therein and whether the scope of application of recital 13 corresponds to the items in articles 10.3 and 11.3 of Reg. (EU) 2020/852. 2. The provisions in article 11.1 should provide additional information on how to calculate the share of eligible and non-eligible economic activities, by setting out whether a specific KPI must be used. 3. Turnover KPI and exclusion of revenues from activities contributing to adaptation (Annex I, 1.1.1). It would be useful to clarify whether these revenues are to be excluded from the numerator of this KPI, except for cases (a) and (b). Also, it is not clear whether these activities need to be Taxonomy-aligned to one of the other 5 environmental objectives or the adaptation one. 4. Regarding business combinations (1.1.2.1), it would be useful to include non-controlling minority stakes. 5. In Annex I, 1.2.1, concerning the changes of the relevant definitions compared to the previous reporting period should be clarified in our view. In addition, in relation to point 1.2.1. c), it would be beneficial to delete this provision or replace it with specific interpretation guidelines addressing how to identify what changes to the CapEx plan are considered to impact past KPIs. 6. In relation to the Contribution to multiple objectives in Annex I (1.2.2.2), it is not clear whether the KPIs are to be disclosed regarding the contribution to multiple environmental objectives or separately for each single objective. 7. In relation to the contextual information about turnover KPI in Annex I (1.2.3.1), it is not clear whether the information about Taxonomy-aligned activities of undertaking generating output for their own consumption should be qualitative only. 8. In Annex I, 2 letter e), it would be useful to clarify why the disclosure of non-eligible economic activities is only referred to the turnover KPI. 9. In Annex II, concerning the Templates for the KPIs of non-financial undertakings. Column 4 and 18 seem to refer to Taxonomy-aligned share of turnover and it is not clear how best they should be filled.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Snam welcomes the opportunity to provide feedback on EC initiative on the revision of the EPBD. Higher climate ambitions require a swift implementation of the Renovation Wave initiative: increased building renovation rates and depth play a key role for a cost-effective transition to a net zero economy. In this view, EPBD revision should aim at: • Setting a clear and stable trajectory via a phased introduction of Minimum Energy Performance Standards (MEPS). In assessing the typology, timeline and scope these measures, the EU should also evaluate how the standards can secure the achievement of the long-term decarbonization goals for the sector. MEPS should be conceived to: 1) leave enough flexibility to MSs to choose the most appropriate and effective way to set these standards; 2) create synergies with other instruments, such as financial and fiscal incentives or technical assistance, making them structural measures. In this light, measures such as the “Superbonus 110%” (an incentivising tax break, currently adopted in Italy) should be encouraged and made permanent, providing long-term visibility. In addition to the generation of positive market and sectorial dynamics, these measures are also needed to mobilise private financing and provide financial resources which, especially for citizens facing energy poverty and often living in poorly performing buildings, would otherwise be prohibitive. • Improving data: reliable, consistent and comparable building data will be of utmost importance to drive the roll-out of MEPS and to guide citizens in their renovation works. Energy Performance Certificates (EPC) should be improved and accompanied by digital individual renovation roadmaps (or Building Renovation Passports). Information should cover also actual performance of a building, to provide transparent and dynamic data on consumptions and to allow energy management, enhancing sector integration. • Fostering the role of effective energy management, as proposed by ESCOs, prioritizing solutions that guarantee a certain level of energy performance or energy savings in the long-term. • Facilitating the renovation of districts and neighborhoods, to maximize energy efficiency renovation and its integration in the energy system. This approach will also facilitate economies of scale, generate new financing and business models, enhance energy communities’ role and enable efficient techs such as CHP. • Achieving cost-effective decarbonization in a system perspective: being a key component of buildings energy performance, heating& cooling need to be progressively decarbonized. A mix of solutions, including low carbon and renewable gases, is key for a cost-effective energy transition consistent with the technology neutrality principle. Most efficient devices installation should be promoted, including gas heat pumps or hybrid solutions (heat pumps and condensing gas boilers) that can be supplied by renewable gases such as biomethane and H2, even blended with natural gas. In order to favor these investments, a crediting mechanism, accounting for the positive impacts of low carbon and green gases should be envisaged. • Including into the optimality methodology besides macroeconomic costs and financial expenditure also a Full Carbon Life Cycle Assessment when setting energy performance requirements for both new and deeply renovated buildings. Finally, the interaction with the other initiatives and policies should form the basis of a thorough assessment to avoid overlapping or inconsistent policies. In line with the above suggestions, the most effective alternative in the Inception Impact Assessment would be Option 3. However, the development of new/enhanced regulatory measures should be combined with non-legislative instruments as listed in Option 2: technical assistance, financial instruments, information campaigns and training programs for the workforce, are essential elements that, if overlooked, could weaken regulatory measures effectiveness.
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Snam calls for expanded TSO role in hydrogen infrastructure development

10 Mar 2021
Topic — EU revision of gas market rules to integrate renewable and low-carbon gases including hydrogen.
Message — The company requests regulatory changes allowing gas transmission operators to invest across the green gas value chain, not just operate networks. They call for flexible hydrogen regulations, support for both blue and green hydrogen, and coordinated infrastructure planning across energy sectors.123
Why — This would let Snam expand beyond network operation into hydrogen production and related investments.45
Impact — Independent hydrogen producers face less separation from incumbent gas network operators with market power.6
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

SNAM welcomes this initiative and considering the draft proposal, we would like to provide the following comments: Hydrogen infrastructure The introduction of a H2 category, including transport, storage, regasification and any other essential asset required to H2 system operations, represents an important progress in building an EU-wide H2 infrastructure. Nevertheless, the current definition of the assets included in this category seems to exclude as eligible PCI “future-proof” infrastructure, i.e. able to operate in a pure H2 context but temporarily operated with gases also in blends with H2. To support the H2 backbone development, the category should clearly include as eligible PCI newly built assets or enhancements/repurposing/reconversion of existing infrastructure insofar they are both ready to manage H2 and functional to the priority corridors development. Project of Mutual Interest Enlarging the scope of priority infrastructure to Third countries brings considerable benefits to the EU as well as to its neighbouring territories both in terms of energy cooperation and other socio-economic impacts. However, the request of a high-level regulatory alignment with EU energy legislation and requirements should be carefully reviewed since it seriously hinders the development of projects with key areas (e.g. North-Africa with its promising decarbonised energy potential or Switzerland, at the crossroads of EU energy grids). Smart gas grids Smart gas grids introduction as enablers for renewable and low-carbon gases integration is welcomed. However, to properly give effect to this definition the projects identified as eligible under this category should include all assets contributing to the decarbonisation of the gas sector, including investment for blending, without a strict limitation to a pre-defined list of elements, which could ultimately prevent technological progresses or the actual elements required for the integration of bioCH4, syngas and H2 into the grids. Further evaluation is needed to understand how the cross-border dimension of PCI fits with this category. Electrolysers facilities The electrolysers inclusion in the TEN-E scope is positive both for the essential sector coupling role and the potential for green H2 scaling-up. Nevertheless, the eligibility of a minimum 100 MW capacity facilities could be challenging to reach for assets rightly requested to have a network-related function. If needed, a capacity threshold could be at least set under a system perspective (i.e. as capacity sum of the set of facilities needed to gas and electricity infrastructural sector coupling). Finally, it is not clear why this category is prevented to access financial assistance in terms of grants for works, considering the amount of resources needed for quick and massive renewable H2 developments (40GW electrolysers by 2030) CO2 Storage The exclusion of permanent storage facilities, as complementary assets to CO2 pipelines, should be reviewed as it is clear the need for a full-chain CCS development, also recognised by the H2 Strategy as an important element for the EU H2 economy taking off New TEN-E transition The current PCI projects should not be reconsidered/removed from the list as they have been selected according to well established criteria and legislation, to avoid disruptions in the commissioning of initiatives identified as priority for market, SoS and sustainability improvements. Planning of H2 infrastructure needs to start immediately to achieve 2030 and 2050 EU targets. Therefore, H2-related projects should be included already in the 6th PCI list to ensure timely investments and accelerate the realisation of the H2 backbone PCI process simplification Unless significant context changes happen, the selected PCI should be able to access a “fast-track” procedure avoiding a full reassessment, limiting administrative costs and providing stability to the projects as important precondition for receiving financial support
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Snam advocates for specific methane rules and investment incentives

26 Jan 2021
Topic — The European Commission is developing legislation to monitor and reduce methane emissions.
Message — Snam supports the OGMP framework but requests segment-specific rules for midstream operators. They suggest exempting small-scale decarbonisation facilities to avoid administrative burdens. Finally, they ask for regulatory incentives to cover emission mitigation costs.123
Why — The company would avoid reporting costs and secure funding for its network improvements.45
Impact — Gas consumers might pay more as regulators approve financial incentives for network operators.6
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Snam welcomes the opportunity to provide feedback to the EC initiative on the draft delegated Regulation on sustainable finance. Competitive financial resources are crucial to foster quick and strong developments of decarbonization activities, ensuring a successful energy transition. A key role to deliver an affordable and secure energy system will be played by renewable/low-carbon gases: future-proofed gas infrastructure and projects require adequate financing access to contribute to the EU Green Deal’s objectives. Snam is fully committed to climate neutrality, planning investments to reduce the environmental impact through innovation with a net-zero company’s target set for 2040. In this perspective, the main messages for the draft Regulation proposals are: • Eligibility of activities making gas infrastructure future-proof. To support the EU decarbonisation strategy, interventions on gas grids are required as from now for making the natural gas transport infrastructure H2-ready,. In light of this, the wording referred to networks as “dedicated to hydrogen” and “repurposed to 100% hydrogen” should be better clarified through the expression “able to transport up to 100% hydrogen”. This would clear all interpretative doubts possibly leading to not recognise as eligible investments those activities required already now for H2-ready gas grids, although operations with pure H2 will materialize at a later stage. Analogous considerations are valid for networks repurposing or replacements, to be classified as taxonomy-compliant activities if the extended lifespan is for H2-ready grids. As for storages, in addition to the construction of new H2 facilities, also repurposing/conversion of existing underground gas facilities to store pure H2 or to increase the H2 blend should be added as activities contributing to climate change mitigation. • Transitional role assigned to activities structural for a net-zero economy. Framing activities such as electricity (co)-generation, manufacturing of biogas and heat/cool production from bioenergy as transitional according to Art. 10 of Regulation 2020/852 could disincentivise investors from allocating resources to sectors that in a medium-long term perspective will have technologically and economically feasible low-carbon alternative, as based on renewable energy. This would undermine their affordable financing, energy supply security at acceptable cost and, ultimately, also decarbonisation objectives. • Methodology to measure CO2 emissions. A zero “direct tailpipe” method to determine CO2 emissions is too restrictive. It would allow as taxonomy compliant exclusively electricity or H2-based technologies with zero emissions at the last user level, independently from the energy origin along the production chain (not necessarily low carbon or renewable). The introduction of a “net-zero” concept or a Life Cycle Assessment (LCA) would better serve the Regulation purposes, guaranteeing that technologies actually have the declared GHG emissions rates. • Technology neutrality principle. Technologies such as steam methane reforming (with CCUS) or hybrid (electricity and gas) heat pumps are not included as Taxonomy compliant, notwithstanding their potential as sustainable activities respectively allowing for: - huge volumes of a low/zero carbon H2 as solution for an early scale-up of H2 market and when applied to bio-based feedstocks, negative emissions outcomes; - the diffusion of hybrid technology solutions avoiding the investment costs both for building renovations and for energy grid enhancements, with beneficial effects in reducing energy poverty. The above-mentioned considerations are detailed in the attached recommendations (amendments to Regulation Annexes specific points).
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Snam welcomes the opportunity to provide feedback to the EC initiative on the review of the EEAG and related GBER rules as main elements of the competition policy to be enhanced mirroring/extending RES provisions to renewable gases, in particular H2, as well as allowing wiggle room for MS to allocate aid to energy infrastructure when needed. Since the publication of EEAG in 2014 EU environmental ambitions have stepped up leading to the publication of the Green Deal and new technological and market solutions - as the ones linked to H2 - have seen unprecedented developments, promising to play a key role for decarbonisation. A revision of EEAG could support Green Deal objectives allowing MS to deliver green economy transition while making the most efficient use of limited public funds. In this perspective, this revision should aim at widening the EEAG scope reflecting: • the increasingly ambitious environmental goals as the GHG emissions reduction targets, recently increased to 50-55% and likely to become even more challenging in the forthcoming “EU Climate Law”; • the economic downturn determined by COVID 19 and its long-lasting consequences; • the residual market failures associated with the lack of recognition of environmental and flexibility/system adequacy externalities by the existing tools (EU ETS/carbon taxes), particularly evident in the case of low carbon and renewable gases; • the latest decarbonisation directions, now hinging on the intertwine between RES and renewable/low carbon gases. More specifically, the revision should aim to: • kicking off green gases (H2 in particular) and the underlying value chains; • promoting energy sector integration and sector coupling for a timely delivery of efficient cross-sectorial decarbonisation outcomes; • enhancing the delivery of clean power (despite most RES technologies would now be in the mature phase). An EEAG broader role should tackle both supply and demand aspects. As for supply side, it would be desirable to introduce provisions for green gases mirroring those related to RES, with particular reference to the inclusion of RES within GBER. However, competing bidding, now the only permitted way of granting operating aid for electricity generation from renewable energy sources, should not be automatically replicable to renewable and low carbon gases. Any support scheme underlying renewable generation should be tailored around technological maturity: at H2 and other low carbon gases early-stage competitive bidding may not necessarily be the most efficient solution. On the demand side, charges reduction to specific category of consumers (electricity-intensive consumers in the case of RES) is another relevant aspect to be extended and appropriately tailored to green gases to favour their scale-up with the identification of relevant consumer categories that should benefit from provisions mirroring the aforementioned. More broadly State aids should ideally be defined in stages. Indeed, the revised EEAG should be aligned to the Green Deal objectives and the EU H2 Strategy, in order to ensure the delivery of the underlying investment targets. Finally, also GBER art. 48.2, limiting aid to energy infrastructure located in assisted areas, would need to be revised. This provision is outdated for the increasingly important role that energy networks are expected to play. In relation to gas networks and the debate on whether/how/when introducing H2 infrastructure regulation, MS should be allowed flexibility in defining how to finance gas grids decarbonisation and to tackle associated risks, particularly relevant in the discovery and scale up phase. Introducing this flexibility could help removing barriers to efficient green integrated energy markets scale up.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

3 Dec 2020 · Hydrogen

Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

Snam welcomes the opportunity to provide feedback to the EC initiative on the Amendment of the Regulation setting CO2 emission standards for cars and vans and would like to provide the following comments and suggestions: 1. Transport and future mobility will be a central element of the climate policies for the coming years. The EU’s long-term climate strategy can rely on an already existing portfolio of solutions including renewable gases such as biomethane (both bioCNG for cars and vans and bioLNG for heavy duty trucks), that can immediately reduce greenhouse gases once displacing the most used fuels such as diesel and gasoline. 2. To facilitate the decarbonisation acceleration, it is necessary to support all low carbon options, including alternative and renewable fuels that can play a role in the energy transition not only on the existing fleet, but also for new vehicles (more and more efficient), considering the lack of a “one size - fits all solution”. In this context, a significant role can be played also by hydrogen technologies, in particular with regard to the “green hydrogen” solutions (H2 produced with electricity provided by renewable energy sources). 3. In addition, the growing rate of sustainable renewable fuels in the market offers sectorial integration with the waste and the agricultural sectors. A Well-to-Wheel approach makes biomethane comparable to 100% renewable electric mobility. Therefore, it is important to consider not only CO2 tailpipe emissions, that represent only a part of the reality. If biomethane from liquid manure is used, the overall emission balance is even negative (see Annex VI of REDII recast) in a perfect sectorial integration with waste management and agricultural sectors. This represents also a landmark example of circular economy targeting emissions in agriculture and waste, where conversion of organic biomasses plays an important role in capturing those methane emissions that would be otherwise released into the atmosphere. 4. It is key to avoid mobility poverty and a two-speed Europe: being based on proven technologies and exploiting an already structured distribution network, sustainable renewable fuels are a cost-efficient way to contribute to the decarbonisation process at the lowest possible cost to society, also through retrofitting interventions. Indeed, besides the costs related to emission reduction, it is important to consider also the impacts on industrial competitiveness, innovation, and employment in order to ensure a fair transition for all European citizens. Considering the above suggestions, we recommend to recognise and include the renewable fuels dimension in the revision of the CO2 emissions standard regulation for vehicles (starting from cars and vans), both in terms of bio-fuels and green hydrogen. Leveraging on the CO2 emissions reduction only at tailpipe level is not sufficient to ensure the shift to carbon neutral mobility. Specifically, the renewable fuels recognised in the context of the CO2 fleet target will accelerate the transition to a real net-zero carbon mobility. The recognition should happen through a new mechanism that encompasses the contribution of renewable fuels when determining manufacturers compliance with their CO2 targets, accordingly to the sustainability criteria of the Renewable Energy Directive and generating additional volumes to it. The inclusion of renewable fuels dimension into the mobility legislation will stimulate the European vehicle industry to further invest in cost-effective and available solutions like CNG and LNG, that also thanks to their progressive evolutions into biofuels (bio-CNG and bio-LNG), can concretely contribute to the mobility decarbonisation.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Snam welcomes the opportunity to provide feedback to the EC initiative on the review of the EU ETS. The primary objective of the ETS revision should be to ensure that the mechanism will provide clear price signals to support decarbonisation meeting the more ambitious climate targets for 2030, as recently revised by the EC. In this view, ETS should first encourage the immediate adoption of the least decarbonisation options already available, such as the fuel switching from oil and coal to natural gas, so that the new climate targets will be attained in the most beneficial way in terms of carbon budget impacts. Along with this, ETS should play a key function in promoting a progressive uptake of renewable and low-carbon gases as key components in the solution for reaching 2030 and 2050 decarbonisation targets at the lowest cost. In particular, the benefits of biomethane and the various types of hydrogen should be recognised in the ETS legal framework proportionately to their greenhouse gas reduction. A Guarantees of Origin (GOs) mechanism should be fully recognised in the ETS as proof of consumption for renewable and low-carbon gases so that ETS operators could benefit from zero, (or reduced) emission rates as additional tool to become compliant with their emission reduction obligations. This would be important for highly GHG-emitting industries (e.g. energy intensive process and power generation), widening the panel of market-based carbon abatement solution on top of other existing choices (e.g. buying emission allowances or changing industrial processes) and stimulating demand for GOs. On the supply side, recognising GOs for renewable and low-carbon gases in the ETS would also incentivise investment cutting their costs down as production scales-up. This trend would reduce the need for other support measures, which could gradually be phased out leaving primarily the ETS market as main stimulus. An ETS revision taking into consideration the extension of ETS scope to other sectors with high GHG impacts, such as transport and heating&cooling where renewable and low-carbon gases already provide effective and affordable solutions to decarbonise, would be another important aspect for achieving more ambitious climate targets. As example, extending the scope of the ETS to transport would stimulate the diffusion of low-carbon and green fuels as viable decarbonisation solutions also in this sector. Here too natural gas (as LNG and CNG) can provide cheap and effective solutions to immediately substitute more polluting fuels, paving the way for infrastructure deployments which will eventually be used for renewable gases whilst already providing significant CO2 and local pollutant emissions reduction (PM, NOx, SOx) compared to the fuels predominantly used. There would be therefore no lock-in effect by encouraging LNG and CNG via the extension of the ETS as the relevant infrastructure would be developed and subsequently used by bio-LNG and bio-CNG (and potentially also by hydrogen). In addition, adopting a full life-cycle CO2 emissions assessment of new heavy goods vehicles (HGVs) would take account of the benefits of advanced biofuels, such as bio-CNG/bio-LNG, which could play a major role in reducing transport emissions (as proposed in Regulation 2019/1242 setting CO2 emission standards for new HGVs). Finally, double environmental taxation burdens are to be avoided ensuring that the revised ETS and other legislative initiatives in climate and energy domains (e.g. Energy Taxation Directive or a Carbon Border Adjustment Mechanism) would cover complementary but distinct applications.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Snam welcomes the opportunity to provide feedback to the EC initiative on the review of the EED, acknowledging energy efficiency as key for a cost-effective transition to a net zero economy (“Energy Efficiency First” principle). The revision should proceed consistently with the Energy Sector Integration and Renovation Wave initiatives. In this view, the most effective approach described in the Inception Impact Assessment would be Option 3, possibly combined with Option 2. An increase in the climate ambition might require enhanced energy efficiency targets: an accelerated deployment of stronger EU policies could help achieving quicker and more efficiently the net zero emission target by 2050. The design of an effective and well-balanced regulatory framework should consider the potential energy efficiency improvements of (green) gases technologies subsequent to their developments in all sectors. The following challenges must be addressed in the EED revision context: • Over complexity. The EU metering and billing framework is currently too complex and unable to incorporate technological progresses: to achieve EU energy efficiency goals stable and certain market rules as well as instruments and methodologies simplifying and optimizing the energy savings quantification and their valorisation are required. In this view, a metering and billing framework based on energy efficiency certification databases would enable reliable information collection on actual consumptions and its delivery to customers, supporting innovation and efficient inspection practices as well as enhancing sector integration. • Market barriers. Difficulties in accessing capital markets and lack of information represent structural obstacles to meet EU energy efficiency goals. • Operators platforms. The development of complete market platforms, where energy saving products can be exchanged providing short and long-term price signals and favouring the information access to operators as well as investment decisions, would promote competition with positive impacts both in terms of savings for citizens and as efficiency gains. Energy efficiency interventions on existing buildings such as insulation and installation of more efficient and innovative devices (e.g. gas heat pumps and micro-CHP as well as hybrid solutions such as heat pumps combined with condensing gas boilers) can contribute to decarbonize the heating&cooling sector. Innovative heating gas techs should be incentivized in order to scale-up and become even more competitive (e.g. micro-CHP with a 95% total heat/power efficiency and gas heat pumps saving >40% of primary energy and recovering energy from the environment). Considering existing buildings renovation constraints (e.g. architectural, historical) these techs can help meeting the efficiency targets with lower system costs thanks to the already widespread gas infrastructure and without requiring deep renovation of the building envelope. Moreover, renewable gases such as biomethane and H2, also blended with natural gas, can be used as fuels. This would make possible to reach net zero or even negative emissions (if biomethane is produced by wet manure) also for hard to decarbonize buildings. In this respect GOs for renewable and low-carbon gases as well as renewable heat certificates would be beneficial. Finally, knowledge dissemination plans together with application standardization are other important elements for the inclusion of these innovative gas techs in renovation plans. National mandatory targets should consider efficiency interventions as alternative to (thermal) renewables incorporation measures, increasing the options that designers can choose in the most convenient way and promoting the development of innovative efficient techs. ‘Primary’ energy consumption (and not “final”) should be always considered to allow a correct comparison between gas and electric techs (energy losses in conversion, transmission and storage must be considered).
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

SNAM welcomes the opportunity to provide feedback to the EC initiative on the review of the EU renewable energy rules (RED II). The revision should proceed consistently with the Energy Sector Integration and H2 Strategies, where the essential role of renewable and low-carbon gases for achieving quicker and more efficiently the net zero emission target by 2050 is clearly defined. In this view, the most effective approach regarding revision of RED II would be the one described in the Inception Impact Assessment as Option 4 (translate into legal measures the actions proposed in other energy strategies of the EGD) providing full support to the further development and use of renewable and other low-carbon gases. To speed up this processes appropriate EU policies and regulatory frameworks are considered as necessary, including: 1. The introduction of an ambitious binding overall EU-level target for renewable and low-carbon gases. The EU target share should then be split down into national target shares according to each MS development potentials (e.g. for biomass, renewable electricity and carbon storage capacity). Such binding target would enhance investor trust and resources needed to support projects at an appropriate scale, bringing down their cost and therefore massively scale-up H2 and biomethane available volumes. It would also allow the EU energy system to follow the trajectory meeting the 2050 climate neutrality target more efficiently and with realistic degree of chance. 2. The development of an EU-wide robust and harmonized certification system for Origin (GOs) and Sustainability. GOs and Sustainability certificates fulfil distinct but complementary functions: a link between the two types of documents would prevent double disclosure of the same energy while offering to operators under EU ETS obligation an additional efficient tool to decarbonize their energy consumptions. The revision of RED II should establish general principles to create such a link. This would also allow GOs to have a role as certificates to be used under obligation schemes to be established at MSs level in order to meet the EU-level target for renewable and low-carbon gases (as proposed above). 3. An obligation for MSs to issue GOs for both renewable and low-carbon gases. As recognised by the EU H2 Strategy, the key role of low-carbon H2 at least in a transitional phase for meeting more ambitious climate targets would be greatly favoured by an extension to all low-carbon gases of the pan-European GO scheme currently under development. The GOs should be the only instrument allowed to prove the origin of gases. 4. The introduction of a common and science-based EU-wide terminology for renewable and low-carbon gases allowing consumers to make correct comparisons between different products and well-informed choices. 5. The introduction of clear criteria for the determination of the renewable content of gases produced from electricity taken from the grid (renewable gases of non-biological origin) and its recognition under obligation introduced by quota systems. A well-established set of rules is crucial for Power-To-Gas (P2G) technology developments as it would help P2G operators to make the most economically and environmentally efficient choices both regarding assets location and investments timing as well as in relation to plants operative periods for converting electricity into H2. A potential role for renewable electricity GOs in this context should be considered while preserving efficient operations of electricity markets. 6. The above considerations will have to be aligned with an appropriate treatment and evaluation of renewable and low-carbon gases imported from outside the EU. 7. Extension of multipliers foreseen in Art. 27.2 to renewable gases (including H2), due to their comparable contribution to achieving (net) zero emissions. 8. Compensation of the principle of additionality (Art. 27.3) also by other instruments like PPAs and GOs.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

Companies under the scope of the NFRD will have to disclose KPIs as percentages of CapEx, OpEx and turnover aligned with the Taxonomy. In order to enhance the applicability of the disclosure requirements as provided by the Taxonomy regulation, some open questions need to be further addressed. In particular, it is relevant to deal with economic activities that do not yet have Taxonomy technical screening criteria (i.e. not yet covered by the EU Taxonomy) while showing positive environmental impacts. The matter has been already treated in the TEG final report. However, it is still unclear if the CapEx, OpEx and turnover those activities generate should be taken into consideration for the KPIs calculation. In case of unavailability or impossibility to calculate a KPI companies should have the opportunity to disclose the reasons behind that. Finally, the assessment of the “do not significant harm” criteria and the alignment to the “minimum social and governance safeguards” have not been clarified if applicable also in relation to the KPIs calculation. In practical terms, for the gas utility sector, it is currently uncertain if some activities could be eligible under the EU Taxonomy or not. This will potentially mean that some initiatives, key to reduce emissions and also constituting a fundamental part of the strategy for utility companies moving towards sustainable activities (such as carbon reduction projects and energy efficiency measures), risk not to be reflected in future Taxonomy disclosure. As a consequence, this would also impact banks and investors as part of their own disclosures. On top of that, there are some projects and activities that may be eligible, but which require further guidance as for example: - “Green Buildings”: it should be clarified that renovations meeting Taxonomy criteria are eligible also in relation to buildings that serve as premises for companies which business is not fully taxonomy compliant; - Biofuels are only included under very strict criteria, while they should as general rule be part of KPIs calculation for their clear environmental advantages; - Clarification that retrofitting the gas transmission network in order to make it H2-ready is an activity environmentally sustainable under the EU Taxonomy. In relation to network retrofitting, Companies would be able to quantify the percentage of the total CapEx as included in their Business Plan. However, it might be more difficult to calculate, in the short-term, the turnover percentage generated by the investment, being unclear if it can be considered also in the timeframe when natural gas is still transported or only when green gases are injected. For gas TSOs it would be also crucial to agree on an extensive definition of gas pipelines retrofit (already included in the EU Taxonomy) so that it will clearly refer to all activities and projects supporting the readiness of networks to transport an increasing percentage of H2 and/or other green/low-carbon gases. Examples of projects should clearly determine the inclusion in the definition of retrofit of CapEx such as i) R&D for green gases transportation and storage, ii) replacement of already existing pipelines with new pipelines certified as “H2 ready” enabling the integration of H2 and other green/low-carbon gases. The disclosure provided by companies allows for a higher transparency into the market but the data available could be processed also by investors in their decision-making process, raising as relevant point the certification of the disclosed data. Indeed, it remains unclear if it is required or recommended that the certification of the KPIs would be performed by third parties and if these subjects should be “accredited verifiers”. Finally, to limit administrative burdens, a parent company should be allowed to produce the relevant reporting on behalf of the group companies.
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Response to EU Standard for Green Bond

7 Aug 2020

Snam welcomes the opportunity to provide feedback to the Roadmap of the public consultation “Ecofriendly investment – EU standard for ‘green bonds” and would like to provide the following contributions. The adoption of an EU Green Bond Standard has the potential to further develop the market of Green Bonds as it provides more clarity for investors and issuers. Additionally, the standard will help to clarify the application of the EU Taxonomy in the context of Green Bonds. We believe the EU Green Bond Standard, despite being voluntary, will become the market standard for the financing of eligible activities. While the EU Green Bond Standards (through the Taxonomy) increase the investable projects and assets in some sectors, it’s key that the new standards do not limit the financing of activities/projects that can provide positive externalities in the transition towards a zero carbon economy. Setting standards in terms of external verification can also have positive effects. However, due to the complexity of the EU Taxonomy, we expect costs for issuers to rather increase than decrease in the future. In addition, it must be ensured that accreditation standards can be met by the current SPO providers who have significantly helped market development and own a more thorough ESG knowledge than classic auditing firms. The TEG has recommended that verifiers of EU Green Bonds should be subject to an accreditation or authorization and supervision regime. Similarly to the accreditation regime for credit rating agencies, such system would provide an independent and harmonized verification of the ability and competence of verifiers to properly carry out their mission. It is essential that verifiers have a deep understanding not only of the EU GBS but of the EU Taxonomy (in particular Technical annex) and are able to judge on the alignment of a green bond with the EU GBS. An accreditation regime would provide comfort to issuers, investors and intermediaries that verifiers have been independently assessed on their ability to properly deliver such service. As the Taxonomy does not yet cover all relevant activities, a certain degree of flexibility should be granted in terms of eligible activities/projects to be financed. Limiting the use of proceeds to only those currently listed in the Taxonomy would significantly lower the opportunities for many potential issuers to become active in the market. It is not considered to be necessary or desirable to introduce new requirements for green bonds into the Prospectus Regulation at this stage as it would not be so relevant to improve the consistency and comparability of information for such instruments and help fight greenwashing. Firstly, the prevalence of green-washing is not, in our view, related to the location of the disclosure, i.e. whether in a framework document or incorporated into a prospectus. So, it is not considered to be necessary because prospectus disclosure for green bonds already follows a relatively consistent approach. Secondly, it is not considered to be desirable because, in absence of an appropriately developed and regulated regime for green / social / sustainability bond framework verification, issuers may not feel comfortable with certain disclosure requirements. So, mandatory disclosure requirements under the Prospectus Regulation could be a disincentive to issuing green bonds (or at least admitting them to trading on regulated markets). The periodic review of the Taxonomy is considered as a positive element. However, the potential risk of a Green Bond no longer being considered green in the future might refrain many corporate from issuing Green Bonds in the first place. It would most likely also cause investors to be much more reluctant to invest as they would then face the risk of having to exit the investment prematurely. Both these negative consequences are likely to occur in particular in the last year(s) before a review is due.
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Snam urges flexible, cost-effective EU methane emission policies

5 Aug 2020
Topic — The EU initiative targets significant reductions in methane emissions to reach climate goals.
Message — Snam advocates for policy tools that offer flexibility to implement technologies for emissions reduction at the lowest cost. They recommend a tailored approach for gas infrastructure to account for the specificity of the gas value chains. Additionally, the strategy should avoid duplication of reporting while supporting innovation and research.123
Why — Flexible regulations would help Snam lower its compliance costs and avoid redundant paperwork.45
Impact — Environmental advocates might see less progress if flexible standards lead to inconsistent monitoring.67
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Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

Snam welcomes the initiative towards a more sustainable and smart mobility model, reducing both environmental impacts and transport costs, improving at the same time people’s life quality and would like to provide the following contributions: 1. It’s key that the initiative is developed in coherence with other work streams. In particular with: • the REDII binding targets on renewable energy (at least at 14%) in the transport sector’s final energy consumption at 2030, with contribution of advanced biofuels (including biomethane) of, at least 3,5%; • the provisions of EU Fuel Maritime initiative; • the revision of AFID: According to a technology neutral approach, need for a Life Cycle (LCA) or a Well-to-Wheel (WtW) assessment to calculate GHG emissions (instead of a pure tailpipe approach) and the inclusion in the perimeter of rail, airport and marine infrastructures for ground movements towards an efficient intermodal mobility; • the CO2 emissions standard regulation for vehicles to be based on a LCA or WtW, in order to properly value the contribution of renewable gases such as biomethane. In this respect, an extension of CO2 credits from fuel to vehicles could allow gas vehicles to access the definition of Low (or Zero) Emissions Vehicles, stimulating manufactures to produce and invest in gas efficient engines. 2. Interoperability among refuelling stations, bunkering operations, and digital solutions across Member States should be ensured through the development of harmonized technical standards and permitting provisions; 3. Strong policy actions should be undertaken through: • Incentives to the construction of gas refuelling stations (i.e. CNG, LNG, Hydrogen), small scale LNG infrastructures and to support new/retrofitted gas vehicles and Fuel Cell Electric Vehicles (FCEVs); • tax exemptions for (bio)LNG/CNG and H2, considering their positive externalities for the environment and the human health, towards a full application of “polluter pays” principle. 4. It is important that research programmes support the innovation not excluding any available technology. The concept of “smart mobility” is closely related to autonomous driving. Automated driving with shared car ownership and mobility as a service (MaaS) will improve economics of FCEVs due to their low operating costs compared to traditional engines. R&D and support for these breakthrough developments should be part of the larger climate agenda. The design of a multimodal transport system of goods and passengers within the EU will be the result of the most efficient and sustainable combination between waterborne, road and railway along the three major transport segments (urban, medium and long-distance transport). In this context, the existing gas infrastructures together with new supply projects (such as micro-(bio) liquefaction plants) and new gas refuelling stations (even in a multi-fuel solution with hydrogen), are the cost-effective already available option to scale up demand of (bio)CNG/LNG, H2 for a multimodal transport (road, shipping and railway). Finally, with particular reference to hydrogen developments as sustainable and smart fuel: - an H2 refuelling station (700 bar), could serve both the fleet of forklifts and material handling systems (AGV, industrial tractors etc.), as well as company vehicles. Furthermore, the same HRS could also supply private cars, public and private buses, transport of municipal waste and trucks. - in the perspective of energy system integration, the infrastructure used to produce hydrogen (electrolysers), also at the filling stations, could be integrated and enhanced to provide flexibility services to the electricity system; - It is crucial the development of a widespread HRS infrastructure starting from the main transport corridors and the most polluted urban areas, in order to achieve the GHG emissions reduction requirements in transport sector by 90% within 2050 according to the “H2 Strategy”.
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Snam advocates for market-based biogas accounting in EU ETS

24 Jul 2020
Topic — Updating rules for monitoring and reporting greenhouse gas emissions within the EU.
Message — Snam proposes adopting a market-based approach using purchase records as the only methodology for biogas. They recommend using guarantees of origin to identify the source of renewable energy. The scope should include decarbonised gases like hydrogen.123
Why — This approach enables operators to secure additional revenues through price premiums for cleaner technologies.4
Impact — Companies using average emission factors may face competitive disadvantages and limited decarbonisation choices.5
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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

Climate change represents a great challenge and will require significant efforts. Considering that ambitious scenarios foresee a maximum of 60% electrification rate, the only way to achieve an efficient and timely energy transition is through the progressive integration of multiple decarbonised energy carries with a balanced mix of sources and technologies. Renewable and low carbon gases (i.e. hydrogen, syngas and biomethane) can be stored, transported and distributed leveraging on the existing, well developed and integrated gas infrastructures, which represent a value not only for the energy systems but also for the overall EU economy and society also considering their crucial support to Circular Economy development. Gas infrastructure shall constitute a pillar of an integrated hybrid energy system where the most polluting fuels are to be quickly replaced by low-carbon and green gases and the full potential of renewable sources is fully exploited. In this perspective, gas infrastructure represents the "back-bone" of the energy systems for an effective, secure and affordable energy transition with climate change impacts contained as much as feasible. To support the long term decarbonization of the energy system (net-zero emissions), Snam is strongly committed on renewable gases development (in particular H2) and in valuating and adapting its asset so that the infrastructure is future proofing (“H2 Ready Network”). Planned investments are directed to enable cost-effective and climate sustainable solutions which can ensure clean energy supplies to EU citizens at the lowest possible cost and contribute to the EU security of supply. With regard to social impacts and effects on human rights proposed for the strategy, we urge that new policies are neither gender nor poor blind but rather look at the intersection of gender and social issues when dealing with climate emergency so as to pursue the goals set out in Art. 7 of the Paris Agreement foreseeing that “adaptation action should follow a country-driven, gender-responsive, participatory and fully transparent approach, taking into consideration vulnerable groups, communities and ecosystems”. Snam agrees with the need to take into full consideration climate risks and effectively address the issues arising from climate change. The commitment and concrete actions to support energy transition are reported in the company annual publications (e.g. Financial disclosure on climate change, Sustainability and Annual Reports): • hydrogen developments, as first EU company to introduce a mix of H2 (up to 10% in volume) and natural gas into its high-pressure transmission network, confirming the suitability of Snam assets to receive increasing quantities of green molecules as future proofing energy infrastructure and their value to facilitate sectors integration • acceleration of biomethane market from organic waste and agricultural or agro-industrial waste in line with circular economy objectives and bringing substantial benefits to the territory and communities involved, such as new jobs and skills as well as economic return for local businesses (e.g. farmers, workers to build and operate new plants) • sustainable mobility, thanks to the promotion of (bio)CNG/LNG and H2 both in terrestrial and maritime transport • energy efficiency solutions for residential buildings, businesses and public administrations; • protecting ecosystems and supporting the resilience of forests and ecosystems through the conservation of existing resources, restoration interventions and sustainable management measures, proven by over than a million trees planted at construction sites and the participation in several initiatives in Italy (aimed at planting 6 Mln trees by 2030) • social projects support, with focus on vulnerable areas, protecting landscapes and the environment, promoted in particular by Fondazione Snam.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

1. Snam welcomes Commission “Renovation wave” initiative for the building sector and would like to provide the following comments: Snam shares Commission view that energy efficiency (especially in buildings responsible for about 40% of EU energy consumptions) is key for a cost-effective transition to a net zero economy. To reach a net-zero emissions target, an increase in energy renovation rates is therefore prominent. Focused policy measures such as long-term renovation targets, increasing required minimal energy performance levels for existing buildings and incentives on energy efficiency measures and low carbon heating systems could help reaching this goal. New measures will have to be considered in synergy with the Energy Sector Integration strategy 2. In our view three elements should be addressed (i) increase renovation speed of all buildings (ii) improve renovation depth (iii) organise decarbonisation renovations for existing buildings in individual renovation roadmaps with light and medium interventions. Although the EPBD sets strict requirements on new buildings, to reduce energy demand and increase renewable energy production in and around buildings (nearly net-zero energy buildings), however it does not set mandatory targets for improving the energy performance of existing buildings. Snam believes that an extension of 3% renovation target envisaged by the EED to the whole P.A. buildings stock should be introduced. 3. Contributions should come from existing buildings requalification via insulation and installation of more efficient devices, including hybrid solutions such as heat pumps and condensing gas boilers. Innovative heating gas techs such as micro-CHP (with a total heat/power efficiency of 95%) and gas heat pumps (which save at least 40% of primary energy and recover renewable energy from the environment) should be incentivized in order to scale-up and become more competitive. Considering renovation constraints on several existing buildings (e.g. architectural, historical) these techs, that can be used with traditional radiators (and no need for very deep renovation of the building envelope), could help meeting the targets with a lower intervention cost for the system, thanks to the well spread existing gas infrastructures in place. These devices can be supplied by renewable gases such as biomethane and hydrogen even blended with natural gas. Such approach could make net zero also hard to decarbonize buildings (even negative if biomethane is produced by wet manure). In this respect guarantees of origins for renewable and low-carbon gases as well as renewable heat certificates would be beneficial. Knowledge dissemination plans together with application standardization are important for the inclusion of these innovative gas techs in renovation plans. 4. Agreeing with “Energy Efficiency First” principle, national mandatory targets shall consider efficiency interventions as alternative to (thermal) renewables incorporation measures, increasing the options that the designers can choose in the most convenient way, and promoting the development of innovative efficient techs. 5. Ensuring that all mature technologies compete in the market is key to have a cost-effective low carbon transition in coherence with the principle of technology neutrality. ‘Primary’ energy consumption (and not final) should be always pursued in order to allow a correct comparison between gas and electric techs, for which energy losses in conversion, transmission and storage must be considered. 6. We suggest promoting a framework on metering and billing enabling, within energy efficiency certifications databases, information collection on actual consumptions to facilitate innovation and support more efficient inspection practices, to provide transparent information to consumers on consumptions and to enhance sector integration. 7. It’s then key to define transparent and stable framework (at least for 5 years) to facilitate access to capitals.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

Snam welcomes the opportunity to provide feedbacks to the Proposal for a regulation - Revision of the guidelines for trans-European Energy infrastructure. In view of the future challenges the EU Energy system will have to face it seems appropriate the EC proposal to think how the Regulation can be reviewed to better address EU decarbonisation targets, being in line with the EU Green Deal goals and policies under design. This in particular with reference to the need to provide adequate support to the development (and adaptation) of green and low carbon gases related infrastructure. A first higher-level element to be considered is that only a well-integrated energy system, building on the complementarity between electricity and gases, will deliver a Union’s decarbonisation path sustainable both environmentally and economically. Therefore, it’s key that TEN-E revision reflects the new hybrid energy system needs as well as gas-electricity interlinked challenges, adopting a technology-neutral balanced approach, avoiding different treatments between the two energy vectors. As TEN-E already supports renewable electricity projects, analogous possibilities must be envisaged for initiatives enabling low carbon, renewable and decarbonised gases related infrastructure developments as eligible PCIs. TEN-E revision should, therefore, open this possibility to gases Energy Transition Projects (ETR), like hydrogen-related developments (infrastructure building/retrofitting and scaling-up technologies such as Power-to-Gas facilities, steam reforming&CCUS and pyrolysis) as well as biomethane and syngas related evolutions. However, adequate consideration should be given also to “traditional” projects as eligible PCIs should they prove to be able to deliver substantial benefits for the energy system as well as the environment. In addition to the above, leveraging on the experiences gained in the previous PCI selection processes we would like to provide the following suggestions: - Sustainability and innovation cross-border dimension: Current TEN-E envisages for PCIs cross-border impact criteria requiring a direct involvement of more MSs or to be located in one MS with significant effects for other MS(s). ETR can substantially reduce GHG emissions having, by definition, cross-border benefits. As GHG emission reduction, also innovation, technology development and upscaling have per se cross-border effects in terms of positive externalities (e.g. knowledge spill-over and cost reductions) and represent common objectives better achieved under an EU perspective. As ETR are sustainable and innovative initiatives, the requirement to involve two or more MSs should not represent a limitation to be selected as PCI. Possible barriers arising from a strict interpretation of cross-border impact criteria should be lifted, especially if requiring unnecessary verification procedures. - Simplification of PCI selection process: once a project is included in the latest PCI list and no major context changes happened between the previous selection processes and the following one, a “fast-track” procedure should be considered. The project should only be monitored and not fully re-assessed unless in case of significant changes or delays, avoiding unnecessary costs and efforts both for the project promoters and the EC (especially for ETR a two-years timeframe may be just enough to start first phases). This solution would provide stability to the list and more visibility to investors who often look at PCI status as a precondition for financing. - Enhancing funding support: to accelerate project commissioning, monetary support represents a high-impact measure to get infrastructure timely in place. For ETR, grants for work (to be complemented by regulatory incentives) could have even a more decisive impact. Additional funding should be accessible within CEF to innovative PCIs, easing at the same time the current requirements in terms of CBCA and commercial viability checks.
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Response to Strategy for smart sector integration

8 Jun 2020

Snam welcomes the “Strategy on the Energy System Integration”, developed in synergy with the Hydrogen and Industrial strategies, as major opportunity to frame a coordinated response addressing both the economic downturn associated with Covid-19 and the climate change challenges. Today natural gas delivers significant value to society across several sectors as: • Energy source for heating in buildings, enabling seasonal coverage of winter demand; • Feedstock in industrial uses and processes; • A flexible energy source in electricity production, more and more needed in the context of increasing RES integration; • A low carbon fuel option (in its compressed and in liquid form) in the transport sector compared to oil; • A key source of security of supply for the energy systems. The role of gases is expected to increase in relevance due to the potential of renewable gases (biomethane and H2 in particular) in terms of decarbonisation and system flexibility. Indeed, the only way to achieve an efficient and timely energy transition is through the integration of multiple decarbonised energy carries encompassing a balanced mix of sources and technologies. It is also evident that decarbonisation cannot be achieved only through total demand electrification: the most optimistic scenarios foresee a maximum of 60% rate of demand electrification. Decarbonisation should be pursued – also with a view to identifying the most efficient solutions – through leveraging on molecules, in particular as applied to the “hard-to-abate” sectors (i.e. transport and industrial thermal uses), and as sources of system flexibility. Renewable, low carbon and decarbonised gases should be therefore seen as a key element for the development of a future EU net-zero emissions energy system. All these gases (i.e. H2, syngas and biomethane) can be stored, transported and distributed leveraging on the existing, well developed and integrated gas infrastructures, which represent a value not only for the energy systems but also for the economy as a whole. In this perspective, gas infrastructures are expected to play a significant role – not only during the transition phase as an enabling factor for the replacement of the most polluting fossil fuels – but more structurally in the long term as energy system "back-bone", being increasingly necessary and essential for the integration: - between the different sectors, in particular gas and electricity, thanks to the molecules potential for long-distance transport and large-scale storage (much greater and secure than electric batteries); - of high shares of non-programmable renewable electricity sources, compensating their intermittence and variability and thus contributing significantly to the flexibility of the system while exploiting their production excesses if transformed in energy resources through renewable gases production (H2 and syngas); - of renewable gas sources, through their injection, transport and distribution in blended form and, in perspective, pure renewable gases, as in the case of H2. However, as for all new technology developments, a successful scale-up of renewable gases production and integration into the energy system requires a supporting policy framework, including the introduction of specific binding targets for renewable gas and a review of market rules facilitating cross-border trade and transport these gases. In this context, where several countries are looking at their own decarbonisation and H2 strategies, a coordinated action at EU level could avoid a fragmented approach, undermining an efficient and effective energy transition, and it would preserve the achievements reached in the creation of an EU internal energy market. Finally, enhanced collaboration on renewable gases with neighbouring countries - e.g. looking at the potential for competitive green H2 imports from North Africa compared to other sources - needs full consideration, also in the context of EU neighbourhood policies.
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Response to A EU hydrogen strategy

8 Jun 2020

SNAM welcomes the opportunity to comment EU Hydrogen Strategy. As the text slightly exceeds the 4,000 characters, our feedback is provided in the attached document.
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Meeting with Kadri Simson (Commissioner) and

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

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

6 May 2020

Snam feedback to Commission delegated Regulation on Minimum standards for EU Climate Transition and EU Paris-aligned Benchmarks Achieving climate neutrality by 2050 represents a great challenge and will require significant efforts. Considering that even the most optimistic scenarios foresee a maximum of 60% electrification rate, the only way to achieve an efficient and timely energy transition and climate neutrality scenario is through the progressive integration of multiple decarbonised energy carriers with a balanced mix of sources and technologies. In fact, gas infrastructures will be able to play a significant role – not only during the transition phase as an enabling factor for the replacement of most polluting fuels – but also in the long term as "back-bone" of the energy systems, increasingly necessary and essential for the integration of: - different sectors, thanks to the gas potential for long-distance, efficient and secure energy transport and seasonally large-scale storage; - high shares of non-programmable renewable electricity sources, compensating their intermittence and variability (thus contributing to the system flexibility) while exploiting their production excesses, transformed in valuable renewable gases (hydrogen and syngas) to be used in all final sectors; - renewable gas sources, through their injection, transport and distribution in blended form and, in perspective, as pure renewable energy vectors, as in the case of hydrogen. In this view, gas infrastructure shall be considered in its potential of green energy carrier on the road to 2050, and not only as a fossil fuel infrastructure. In particular, as hydrogen and other green gases represent green energy vectors point f) of article 11 should be amended as follows: “companies that derive 50 % or more of their revenues from the exploration, extraction or manufacturing of hydrocarbons and carbon monoxide mixtures present in gaseous state;” The European Green Deal’s ambition needs to translate into significant public and private investments in energy efficiency, renewable energy, new low carbon technologies, and grid infrastructure. Infrastructure used today for hydrocarbons will gradually shift towards increasing shares of renewable gases (including hydrogen) strongly contributing to the achievement of Paris agreement targets at sustainable costs. Additionally, as for letter g) of article 11 a threshold set at 100g CO2 e/kWh is something which does not even allow to include the present “best performance” plants, also taking into account an increased share of biomethane (or other green-gases) in the future. In a recent study from Navigant (now Guidehouse) it has been found that a smart combination of hydrogen and biomethane with electricity is the optimal way to decarbonise the energy system. Using green hydrogen and renewable methane through existing gas infrastructure across the EU could save society over €200 billion annually by 2050.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

Snam welcomes the opportunity provide feedbacks on the potential AFID revision, being a key instrument for the development of markets for alternative fuels, and would like to provide the following comments and suggestions: 1. A long term and stable regulatory framework as well as a clear long-term plan for each fuel is key to invest in alternative fuels infrastructure. 2. The initiative should be coherent with the REDII binding targets on renewable energy (at least at 14%) in the transport sector’s final energy consumption at 2030, considering a contribution of advanced biofuels (including biomethane) of at least 3,5%. 3. New AFID should adopt a technology neutral approach and consider the Life Cycle Assessment or a Well-to-Wheel approach to define the GHG emissions (instead of a pure tailpipe approach). A Well-to-Wheel approach makes biomethane comparable to 100% renewable electric mobility. If biomethane from liquid manure is used, the overall emission balance is even negative (see Annex VI of REDII recast ) in a perfect sectorial integration with waste management and agricultural sectors. 4. Interoperability across Member States should be ensured through the development of standards and harmonized procedures, especially on safety and permitting provisions for CNG and LNG stations. 5. In general, financial incentive should promote available and affordable alternative fuels considering in the cost and benefit analysis also the advantages of shorter refuelling time and longer distance autonomy (typically for CNG/LNG and hydrogen). 6. It is important that the research programmes do not neglect support for innovation in the sector of renewable fuels. As regards the development of (bio)CNG/LNG as alternative fuels: 1. (bio)CNG/LNG supply and refuelling system should be supported until they reach a mature market development all over Europe. Gas fuelling stations can rely on a well spread gas infrastructure in Europe and can be multi-fuel stations, integrating different alternative fuels (hydrogen in primis). The focus of the incentive schemes should not only be on the refuelling stations, but on the overall supplying system, including micro (bio)liquefaction plants, small scale LNG terminal and bunkering solutions from which the stations will be supplied. 2. In addition, also the market uptake of new and retrofitted CNG/LNG vehicles and LNG vessels should be supported. CNG and LNG vehicles produce less CO2 eq, NOx, SOx and PM emissions than the currently used fuels. These benefits can be maximized using (bio)CNG/LNG. In the transport sector specifically, some gas suppliers are already offering 100% renewable gas and an increasing number of fleet operators are committed to switching to 100% renewable gas fuelled transport. Such initiatives should be encouraged by appropriate legislative tools incentivizing biomethane usage for transport. With reference to hydrogen development as alternative fuel: 1. To meet the GHG emissions reduction requirements in transport sector by 90% within 2050, also the adoption of Fuel Cell Electric Vehicles (FCEVs) is crucial to achieve the long-term climate goals without releasing other harmful pollutants such as NOx, Sox or PM2.5. 2. A successful long-term decarbonisation largely depends on the construction of the necessary infrastructure for refuelling hydrogen also through multi-fuel stations. A prerequisite for its realisation is the combination of existing programmes (such as TEN-T and TEN-E corridors) and available or new finance/guarantee tools. 3. To ensure a level playing field with other alternative fuels the Directive should support hydrogen refuelling stations, envisaging a review of National Policy Frameworks and binding targets for the Member States encouraging strategic planning of hydrogen refuelling infrastructure in collaboration between public and private stakeholders. (https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018L2001&from=EN)
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Response to Climate Law

1 May 2020

Snam, as one of the world’s leading energy infrastructure players, welcomes the opportunity to provide a first feedback to the European Climate Law Proposal. Achieving climate neutrality by 2050 represents a great challenge and will require significant efforts. Considering that even the most optimistic scenarios foresee a maximum of 60% electrification rate, the only way to achieve an efficient and timely energy transition is through the progressive integration of multiple decarbonised energy carries with a balanced mix of sources and technologies. Today gas is a key energy source for Europe in: - heating in buildings, enabling seasonal demand coverage; - electricity production, providing flexibility for increasing RES integration; - industrial uses, as feedstock or unique vector for high-energy intensity processes; representing also one of the cleanest fuels in the transport sector (in its compressed or liquid forms). The presence of gases in the EU energy mix shall be supported and even increased thanks to the renewable gases potential for decarbonization, ensuring at the same time flexibility and security of supply for the energy systems as well as an affordable transition for the EU economy. Renewable and low carbon gases (i.e. hydrogen, syngas and biomethane) can be stored, transported and distributed leveraging on the existing, well developed and integrated gas infrastructures, which represent a value not only for the energy systems but also for the overall EU economy. Gas infrastructures will be able to play a significant role – not only during the transition phase as an enabling factor for the replacement of most polluting fuels – but also in the long term as "back-bone" of the energy systems, increasingly necessary and essential for the integration of: - different sectors, thanks to the gas potential for long-distance, efficient and secure energy transport and seasonally large-scale storage; - high shares of non-programmable renewable electricity sources, compensating their intermittence and variability (thus contributing to the system flexibility) while exploiting their production excesses, transformed in valuable renewable gases (hydrogen and syngas) to be used in all final sectors; - renewable gas sources, through their injection, transport and distribution in blended form and, in perspective, as pure renewable energy vectors, as in the case of hydrogen. Additionally, renewable gases have the further potential to achieve negative emissions (e.g. by coupling the use of bio-energy with CCS), which will be essential to achieve net-zero emissions by compensating for emissions in more challenging and expensive sectors to decarbonize (e.g. agriculture, heating or transport). However, as for all new technology developments, a successful scale-up of renewable gases production and integration into the energy system requires clear and supportive policies. An ambitious EU binding threshold for renewable gases by 2030 is key for an increase of the EU GHG reduction target to 50-55%, as it would stimulate the demand and the penetration of low carbon gases into the energy mix. This threshold should progressively increase towards 2050 to support the trajectory leading to zero emissions. Policy makers should introduce measures to achieve these targets and tailor both targets and measures to the different sectors, depending on the potential of low carbon gases as applied to the specific contexts. These would represent valuable and concrete policy measures to provide the energy system with a clean supply mix with the needed flexibility and at the most efficient cost for society. To further support the trajectory for achieving climate neutrality, the targets should be accompanied by a review of market and technical rules facilitating efficient transport and cross-border exchanges of low carbon and renewable gases, primarily a well-functioning Guarantee of Origin scheme as well as the ETS strengthening and broadening.
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Response to FuelEU Maritime

24 Apr 2020

Preliminary Snam inputs to the FuelEU Maritime Initiative Snam, as one of the world’s leading energy infrastructure players, welcomes the FuelEU Maritime Initiative and provides the following contributions: 1. The initiative should take a well-to-wake approach, and consider not only the impact of GHG but also of local pollutants. LNG produces less CO2 eq (-21% GHG emissions), NOx, SOx and PM emissions than the currently used fuels: Heavy Fuel Oil (HFO) and Marine Diesel Oil (MDO). These benefits can be maximized using BioLNG. LNG permits ship-owners to comply with the emission limits set by the International Maritime Organisation (IMO): a. SOx limit in Emission Control Areas (ECAs) 0.1% from 2015; b. SOx limit in other marine areas 0.5% from 2020: LNG’s SOx is 1,000 times lower than the IMO 0.5% rule; c. The Tier II limits NOx in global seas and Tier III in ECAs that were introduced in 2016: LNG can reduce NOx by up to 95% and PM by 99% compared to HFO. 2. Growing LNG demand for shipping can be sourced from existing LNG import facilities in Europe. Using existing assets and developing new projects in small size liquefaction plants (supplied by the gas grid or by biomethane plants for bio-LNG) can be a cost-effective way to scale up demand. Following the implementation of the Alternative Fuel Infrastructure Directive, LNG will be available in EU TEN-T core ports by 2025, enabling the LNG shift for the shipping sector. 3. Annualised CAPEX for ships is low due to the long lifetimes (25-30 years) of ships and, the use of technologies with low operating (fuel) costs, such as affordable and worldwide available LNG are essential. However, the transformation of the shipping is slow due to the rate of unit replacement. Under current EU policy, limited developments are foreseen in the sector before 2030. Most of new ships are built and sold in East Asia, which could reduce the impact of European-only policies. To reach net zero emissions by 2050, only new vessels with engines that use or can be retrofitted to use low carbon fuels should be accepted in shipping, before 2025 or sooner if possible. It requires strong policy action to stimulate early switching to low/zero emission ships through (bio)LNG, – one of the main fuels for a net-zero carbon emissions maritime transport – and other low carbon fuels. 4. To reach a net-zero carbon maritime transport sector by 2050, we propose the following actions: • EU-wide development of fuelling infrastructure for (bio)LNG in shipping (both waterways and seaports), to ensure a proper fuelling infrastructure in place across Europe. • A progressively increasing mandatory target for alternative fuels such as (bio)LNG for the full transport sector - including shipping - could be a complementary solution to ETS. • Development of policies and regulations to incentivise (1) the construction of the Small Scale LNG infrastructures (i.e. microliquefaction plants and LNG storage tanks) to increase the volume of (bio)LNG and (2) shift to vessels that operate on low carbon fuels, including ship design standards (LNG-ready) allowing retrofitting of engines. • Tax exemption for alternative fuels such as (bio)LNG and port tariffs reduction for LNG vessels. • Enabling the introduction of a 0.1% SECAs in other regions such as the Mediterranean as mutually agreed with IMO. • Incentivizing the use of (bio)LNG for ports cold ironing by trucks. • Supporting R&D for innovative solutions for vessels and ports to further reduce methane slip, considering that methane slip from LNG ships has decreased 4 times since 1990s and that ongoing activities are continuing to reduce it. • Harmonization of rules to ensure transport will be able to operate internationally. The more so for shipping, considering its intercontinental dimension.
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Response to Climate change mitigation and adaptation taxonomy

24 Apr 2020

Preliminary SNAM inputs to the Commission Delegated Regulation on a climate change mitigation and adaptation taxonomy Snam S.p.A. is one of the world’s leading energy infrastructure player which operates in Italy and through its associated companies also in Albania, Austria, China, France, Greece and the United Kingdom. Snam is also one of the main shareholders of TAP (Trans Adriatic Pipeline). We welcome the opportunity to provide first feedbacks to the Commission Delegated Regulation on a climate change mitigation and adaptation taxonomy, based on the contents of the inception impact assessment. In this respect we would like to share the following comments and contributions. TRANSITION – ROLE OF GAS The TEG report confirms that the EUTAX is based on a binary model (“green”/”no green”), considering aligned those activities/sectors “already low carbon” and including in this category also those being transitional activity and enabling activity. The definition of “transitional” when being referred to the (natural) gas sector is however very narrow, for instance in the electricity generation through gas-fired plants, with a threshold set at 100 gr/kWh to be reviewed every five years to reach zero emission by 2050. This approach is, de facto, very restrictive for gas utilization considering that the defined threshold is something which does not even allow to include the present “best performance” plants, also taking into account an increased share of biomethane (or other green-gases) in the future. Therefore, TEG proposal might in the end not include a real and practical concept of transitional period. Supporting a transitional period to be used for the gradual development of low carbon gases without taking into account the use of an enabling share of natural gas would not be effective. Consequently, a review of the threshold - considering the state of the art of the best available technologies - is necessary to set the starting point of a trajectory leading to zero emission by 2050. Furthermore, the growing share of non-programmable renewable sources will make the energy system potentially more exposed to critical situations. In order to help a safe and sustainable energy transition, natural gas and low carbon gases can provide a higher level of security of supply and foster a better integration of renewables. HYDROGEN AND OTHER LOW CARBON GASES Regarding hydrogen, retrofit and adaptation of the existing networks are considered as aligned to EUTAX. This is positive, but in order to provide more clarity to investors it should be specified that retrofit and adaptation are considered from the moment the investments take place (i.e. investments are “future proof”), regardless the immediate transportation and distribution of hydrogen. This should not only refer to networks but be applicable as well to other gas infrastructure. Also, expansion of gas networks/infrastructure to support transportation and development of hydrogen and other low carbon/green gases shall be explicitly considered, particularly to be appreciated with regards to the local context, the energy mix of the country and available alternatives. In some countries or specific regions no renewable alternatives are immediately available and gas, after achieving a positive cost benefit analysis which also takes into consideration environmental criteria, could substitute more polluting fuels such as oil or coal. In line with the EUTAX objectives it would be also necessary and beneficial to explicit mention biomethane. SUSTAINABLE MOBILITY CNG/LNG are key fuels for the energy transition. In this respect they shall be part of the framework for all possible uses (maritime, heavy and road transportation), especially in a gradual process of increasing share of low carbon gases such as biomethane to be dedicated to this sector. Snam would be pleased to provide the EC with further information and evidences supporting the contents briefly reported in this short memo.
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Response to 2030 Climate Target Plan

15 Apr 2020

Preliminary Snam inputs to the 2030 Climate Target Plan Snam S.p.A. is one of the world’s leading energy infrastructure player. We welcome this opportunity to provide a first feedback to the 2030 Climate Target Plan based on the contents of the Inception Impact assessment. Europe is setting for itself very ambitious targets for 2030 and 2050 to increase its sustainability and reduce the economy carbon footprint. Any 2030 target should be put into the perspective of a full decarbonization by 2050 and hence embrace all sectors and energy uses. An effective and sustainable decarbonisation pathway, ensuring safe energy at the lowest possible cost for consumers, requires a coordinated approach by the various energy players. In this respect, natural gas and renewable gases are well placed to support the decarbonisation energy system by 2030. Gas infrastructure - and networks in particular - can play a fundamental role in the energy transformation, as a flexibility tool to enable the integration of an increasing number of non programmable renewables (through conversions of electricity into gas and vice versa) and being itself the carrier of renewable energy (i.e. green-gases). Gas infrastructure can represent a pillar of an integrated hybrid energy infrastructure, which will allow to exploit the full potential of renewable sources, also ensuring medium-long term energy storage and security of energy supply. In the very short term, natural gas will play a key role, responding to the urgent need to replace most polluting sources, such as coal, lignite and oil products. A swift coal-to-gas switch and an increased use of gas-based cogeneration systems will provide substantial emissions reductions and increase energy efficiency for power generation and for heavy hard-to-abate industries, thanks to a lower carbon intensity (CCGTs halves the emissions of a coal power plant). In the transport sector, natural gas used in various forms (CNG/LNG) offers today an affordable option for consumers to reduce immediately emissions and pollutants compared to gasoline or diesel. At the same time, the development of renewables and low carbon gases will also play a relevant role in the decarbonisation of final uses. In order to further reduce emissions, several studies have shown that it is possible to significantly scale up renewable gases production (e.g. biomethane from several sources, hydrogen and synthetic methane), leveraging on existing gas infrastructure with significant savings compared to other scenarios that exclude renewable gas uses. Another element to consider is the efficient use of the existing EU gas system. To meet the targets, it is essential to also look at the potential and the opportunities arising from green gases supplies (hydrogen and biomethane) from renewable or zero-emission sources from EU and non-EU countries (e.g. North Africa). The choices of energy and environmental policy must be inspired by energy efficiency and technological neutrality and enhance the existence of a significant infrastructural heritage: i.e. gas transmission and distribution networks, LNG terminals, storage sites as well as redelivery points to filling stations for CNG. Infrastructure system that guarantees the EU high continuity and security of energy supplies to meet its consumers’ needs. In order to promote the development of renewable gases, the EU regulatory framework needs to be enhanced to support the entire value chain development, guaranteeing an accelerated decarbonisation path with economic and employment benefits. Among others, an ambitious EU binding target for renewable gases by 2030 would stimulate the demand and the penetration into the energy mix, while the creation of an EU GO scheme will allow for a mutual recognition of renewable gases and promotion of an efficient cross-border exchange. Snam would be pleased to provide the EC with further information and studies supporting the contents briefly reported in this short memo.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

The following points referred to the EC Inception Impact Assessment intend to represent a first SNAM contribution to proposal for a “Carbon Border Adjustment Mechanism” Directive. • European economy competitiveness shall continue to be a key goal for EU policy, being strictly linked to employment levels and, in general, to the overall internal wealth. In this perspective, measures aimed at safeguarding the competitiveness of European industries are imperative, especially if directed to offset the effects of an increased cost of production linked to choices aimed at fostering the energy transition towards a low carbon economy. • A mechanism to reduce the risk of carbon leakage as well as EU industries being less competitive due to higher energy costs is therefore deemed as an appropriate measure bringing together also valuable economic and social impacts. Indeed, production activities set up (or relocated) outside Europe only for exploiting lower energy costs for the absence of negative externalities correction mechanisms (e.g. Emission Trading System or other arrangements in the EU framework, such as Energy Taxation Directive) determine a net adverse environmental balance at global level. • European industry is characterised by a top-class energy system for reasons linked to both technological and legislative evolutions. Such a competitive advantage should not be undermined by the introduction of the virtuous legislative provisions envisaged under the new EU Green Deal aimed at safeguarding the environment. In this perspective, a “Carbon Border Adjustment Mechanism” could defend EU economy on the one side against delocalisation choices and on the other side from competition against goods produced at lower costs by using more polluting fuels. This would have a double negative effect: on society, for the loss of local employments and skills, and on environment, since the overall pollutants level is not reduced, being GHG emitted elsewhere in the atmosphere. • Additionally, we share the view that a “Carbon Border Adjustment Mechanism” would contribute to the enhancement of the Renewable Energy Sources (RES) diffusion both in and outside Europe. In particular, a well-designed and properly implemented adjustment scheme could prevent obstacles in the development of renewable gases technologies and the whole supply chain needed to support the energy transition (biomethane and hydrogen newly-born European sectors), that could be endangered by distortive/unfavourable competitive conditions. • The “Carbon Border Adjustment Mechanism” should be also designed to consider the effects of the policy decisions on export goods in order to keep the competitiveness of EU industries at global level. In this respect, if an increase in costs for imported goods produced with more polluting fuels will be put in place, equally also a “discount” for exported goods have to be envisaged if those products are produced with low carbon and/or renewable sources (such as biomethane, syngas, hydrogen and abated natural gas). • When designing the legislative measures establishing the Mechanism, a correct link with EU Emission Trading System and Energy Taxation Directive should be ensured to adequately reflect in the imported products prices the cost of carbon as well as the different taxation levels applied to energy sources according to their environmental and social impacts. • A “Carbon Border Adjustment Mechanism” would allow to gradually overcome the free allowances granting system - introduced also for mitigating the carbon leakage risk – so that the cost of carbon would be correctly reflected in all the economy sectors.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

The following points referred to the EC Inception Impact Assessment intend to represent a first SNAM contribution to the Energy Taxation Directive revision process. • It is important that natural gas taxation regime in the different sectors is kept at the current levels (or even reduced), taking also into account the increasing percentage of low carbon and green gases (biomethane, blue and green hydrogen) in the overall gas system. The current taxation regime is a key enabling factor both for the substitution of more polluting fossil fuels with natural gas in the short/medium term and with lower to zero carbon renewable gases in the medium/long term. A well-designed and balanced taxation regime is crucial for the development of the whole supply chain of renewable gases, underlying biomethane and hydrogen newly-born industries. In the transport sector particularly, CNG and LNG will progressively include higher shares of biomethane: keeping a favourable taxation regime is therefore crucial to foster gas demand in transports and the diffusion of low carbon fuels, to allow them to become even cleaner and, ultimately, to reach carbon-neutrality. The deployment time is considered to be of at least 10 years. • Should the Energy Taxation Directive consider a tax scheme based on GHG emissions, a Life Cycle Approach should be adopted for emissions’ calculations. The emission coefficients should be established at levels which promote the penetration of low-carbon gases first and ultimately of green gases, supporting the energy transition. In this perspective, the coefficients should not only be set based on natural gas CO2 emissions, as they could be representing a partial view, not properly considering the important contribution to local pollutants, and risking to impede and/or stop the full development of low carbon gases which are in any case needed to allow for a substantial improvement of the transport sector footprint. • The new taxation scheme should therefore consider not only GHG emissions but it should also take into due consideration other pollutants, such as Particulates and NOx, having serious negative impacts at social and environmental levels. • In order to avoid double taxation effects, electricity used to produce green hydrogen (power-to-hydrogen) or synthetic biomethane (power-to-biomethane) shall be exempted from taxation on a mandatory basis. Snam is currently working on a specific study in collaboration with a Research Institute on gas taxation in the transport sector subject which will be ready in few weeks and that we will be pleased to share with the Commission if deemed useful.
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Meeting with Miguel Arias Cañete (Commissioner) and ENEL SpA and

6 Jun 2019 · Long Term Strategy

Response to European standards for alternative fuels infrastructure for L vehicles, shore-side electricity for inland navigation ves

12 Apr 2019

Referring to the article 3 of "Draft delegated regulation - Ares (2019) 1728567", we believe that three critical issues could arise from its implementation. The first, concerns the implementation of the EN 16723-2 standard with particular reference to the sulphur limit provided for CNG / biomethane for automotive use. The EN 16723- 2 should be referenced only as recommended and not mandatory. As a matter of fact, the provisions of the standard go against the minimum concentration value of odorant required by the Italian Law in order to guarantee the safe use of natural gas used in distribution networks. While awaiting a revision of this minimum value and the introduction of a maximum value of odorant in line with the European standards, the filling stations connected to distribution grid, in order to comply with the aforementioned limit, should therefore install sulphur reduction devices that could penalize them from the financial point of view. As far as the fuelling operation is concerned, the second issue concerns the adoption of the “temperature compensation” provided by EN ISO 16923. The vast majority of the dispensers installed in the Italian filling stations (total 1300 stations) should be replaced and it will lead to a massive increase of costs for the filling stations. We propose that the current Italian practice should be maintained without any change (i.e. filling tanks at 220 bar) provided that a minimum filling temperature is established for sites providing L-CNG at very low temperatures. As a matter of fact, the current Italian practice has never produced any safety problem in filling operation during decades of observation. Lowering the filling pressure from 220 bar to 200 would greatly damage the CNG market in Italy. Finally, referring to the implementation of the EN 16723-2 standard, we underline another important topic regarding the hydrogen limit. By requiring fuel quality to comply with the standard at refuelling points, a legal barrier to hydrogen injection in gas grids beyond 2% in volume may be unintentionally established while technological developments in the short or mid-term can make this requirement obsolete. Therefore, we suggest providing flexibility to Member States to increase the hydrogen concentration limit at refuelling points.
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Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

5 Sept 2018 · State of play TAP, EU-China Cooperation, 2050 Communication, Greece DEFSA privatisation

Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete)

23 Apr 2018 · development of biomethane

Meeting with Miguel Arias Cañete (Commissioner)

12 Apr 2018 · role of gas

Meeting with Miguel Arias Cañete (Commissioner) and Enagás S.A. and Fluxys SA

30 Jan 2018 · Trans-Adriatic Pipeline

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

6 Jul 2017 · Southern Gas Corridor

Meeting with Maroš Šefčovič (Vice-President) and

27 Apr 2017 · State of play TAP

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

18 Apr 2017 · State of play TAP

Meeting with Maroš Šefčovič (Vice-President)

24 Mar 2017 · Ukraine, TAP, G7

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

9 Feb 2017 · Gas Infrastructure

Meeting with Dominique Ristori (Director-General Energy)

19 Dec 2016 · gas market developments

Meeting with Maroš Šefčovič (Vice-President) and

19 Dec 2016 · State of play Southern Gas Corridor

Meeting with Dominique Ristori (Director-General Energy)

18 Jul 2016 · Energy policy

Meeting with Maroš Šefčovič (Vice-President)

9 Jun 2016 · Evolution of EU Gas market, interconnections with LNG

Meeting with Dominique Ristori (Director-General Energy)

9 Jun 2016 · Energy policy

Meeting with Miguel Arias Cañete (Commissioner)

9 Jun 2016 · Presentation of SNAM, European gas infrastructures and vital projects

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

31 May 2016 · Preperation meeting VP Sefcovic CEO SNAM

Meeting with Dominique Ristori (Director-General Energy)

26 Apr 2016 · Energy policy

Meeting with Miguel Arias Cañete (Commissioner) and BUSINESSEUROPE and

18 Feb 2016 · Market design

Meeting with Gonzalo De Mendoza Asensi (Cabinet of Vice-President Miguel Arias Cañete)

28 Jan 2016 · MidCAT state of play

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

30 Sept 2015 · Gas strategy and infrastructure

Meeting with Maroš Šefčovič (Vice-President) and

1 Sept 2015 · Presentation of company, gas strategy and infrastructure

Meeting with Miguel Arias Cañete (Commissioner) and

4 Jun 2015 · Presentation of the SNAM Company strategy

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

20 Jan 2015 · Presentation of Company activities