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ΔΙΑΧΕΙΡΙΣΤΗΣ ΕΘΝΙΚΟΥ ΣΥΣΤΗΜΑΤΟΣ ΦΥΣΙΚΟΥ ΑΕΡΙΟΥ Α.Ε.

ΔΕΣΦΑ Α.Ε. /DESFA SA

The Hellenic Gas Transmission System Operator (DESFA) S.A.

Lobbying Activity

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 Mario Nava (Director-General Structural Reform Support)

10 May 2022 · Bilateral meetings with CEO of DESFA, Mrs Maria Rita Galli - exchange on the REPowerEU, with a focus on the reforms and investments for Greece.

Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

DESFA welcomes the EC initiative for a revised TEN-E Regulation aligned with the new EU Green Deal goals. We are providing the following suggestions per topic with the intention to support the necessary improvements in the draft proposal. • Energy infrastructure categories The gas infrastructure has an important role to play in the transition to net zero emissions economy by repurposing/retrofitting existing pipeline systems, gas storages and LNG terminals. DESFA welcomes the recognition of repurposing in the draft proposal as well as the addition of priority thematic areas and the categories for smart gas grids, hydrogen and electrolysers in TEN-E Annexes I & II. We note that hydrogen infrastructure, new or repurposed, might have to temporarily operate with blends of natural gas with hydrogen and low-carbon gases. Therefore, the thematic areas should be expanded to clearly address the retrofitting of gas networks for blends, as this will also play a major role in some sectors and regions. Furthermore, any assets required for enabling and facilitating the integration of renewable and low-carbon gases into the network should be covered by the smart gas grid category. DESFA believes that the Commission's proposal to exclude all traditional gas projects will likely be counter-productive to trajectory to its Green Deal objectives, and should therefore be reconsidered. There are currently EU member states with a high reliance on coal and oil, where gas can provide a transition to renewable energy through use of highly efficient and hydrogen-ready CCGTs and CHPs, combined with growth in renewables. Regarding CO2 infrastructure, the exclusion of CO2 storage facilities, other than buffer storage, seems to be inconsistent with the need for full-chain CCS technologies. • PCI list and eligibility criteria We agree that sustainability has become the key objective for EU’s energy sector, but the objectives related to the Internal Market and SoS are still important cornerstones in EU energy policies and must not be neglected. Current PCI projects should remain in the future list as necessary to realise the expected market and SoS improvements. Unless significant context changes, the already selected PCI can be able to access a “fast-track” procedure avoiding a full reassessment, limiting administrative costs and providing stability to the list as important precondition for receiving financial support. • Network planning The inclusion of hydrogen projects in the 6th PCI list is necessary to ensure timely investments and the achievement of the European Climate and Energy targets for 2030 and 2050. The TEN-E regulation should also consider other measures such as the construction of infrastructure triggered by the development of renewable methane (biomethane and synthetic methane) for PCI status. Regarding offshore grid planning, hydrogen pipelines and gas production facilities can play an important role in the development of offshore networks. DESFA suggests that this provision is reconsidered to determine how best to include this to ensure an effective and integrated planning and investment procedure for the offshore grids for both electricity and hydrogen. • Projects 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. Apart from sustainability, market integration and SoS are important criteria for these, and infrastructure to be developed should be future-proof to accommodate hydrogen and renewable gases, but blends should be temporarily acceptable.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

DESFA recognizes that the EU's financial mechanisms will play a key role in accelerating investment in technologies that allow us to move forward on the road to carbon neutrality. These technologies should allow a high proportion of renewable energy to be incorporated into the energy system by 2030. Already today gas plays an important role in balancing interruptible renewable energy sources at affordable cost, reducing CO2 emissions and ensuring the reliability of the system. The use of natural gas is an important technological solution for the regions, each with different starting points, which will have to transform the use of energy sources. As the new, higher climate target requires the rapid development of renewable energy sources by 2030, the exit from high-emission technologies must not jeopardize the stability of energy systems. The particularly efficient use of natural gas in cogeneration can play an important role in balancing the network and gas cogeneration plants can improve air quality in cities across the EU. This is particularly crucial for Greece, which is called upon to contribute in an equal manner with the other Member States to the EU's environmental, ambitious objectives. Greece must stimulate development, both for production and demand, of a new market for pure hydrogen. For this to happen, however, it is necessary first to achieve the greatest possible penetration of natural gas throughout the territory. The development of an extensive network, from the outset, ready to accept its full transformation into a net hydrogen network, through the gradual mixing of gas with renewable gases (hydrogen, biogas), will help to create the hydrogen market whenever such a market becomes possible. The eligibility criteria proposed according to the type of gas moved give a clear precedence to Member States which have long-term use and an extensive natural gas network. In the case of electricity generation, the proposed technical criteria for carbon dioxide emission of the classification exclude the use of natural gas, setting unattainable limits. This will result, if we also consider the phasing out of the use of lignite to which Greece has committed itsself, the large increase in energy costs and the dependence on imports, which, in principle, will come from countries that produce energy from less clean energy sources than Greece. And the effects of such a development may be significant for the stability of the operation of the country's energy system. Further linking EU funding mechanisms to the taxonomy regulation, which would exclude gas as a viable option for coal-dependent regions, could only undermine ongoing transition efforts, prevent the development of renewable energy sources and expose citizens to energy poverty. A successful energy transition on this scale requires an adequate set of investment messages across the EU, which takes into account regional conditions, and ensures that no one is left behind. Therefore, significant regional specificities throughout Europe should be recognized through the delegated acts under the classification regulation and through the EU funding mechanisms that can work for all. Well-designed EU financial mechanisms should allow for the rapid replacement of coal with natural gas as a transitional solution, where other options are limited, to bridge the gap in investment and technology and to help the regions currently dependent on coal by transforming them in the coming years. The attached text proposes specific amendments to the technical eligibility criteria and provides the necessary explanations.
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