Letter: Call for a technology-inclusive revision of the TEN-E Regulation
To: EU 27 Energy Ministers
Cc: EU 27 Permanent Representations
Brussels, 4th June 2021
We, the signatories of this letter, support the goals of the Paris Agreement and the EU’s objective of climate neutrality by 2050. Their achievement will require the EU to use a broad range of solutions and technologies to reduce emissions, including Carbon Capture and Storage (CCS) and Carbon Capture and Use (CCU) as effective climate-mitigation tools.
We welcome the proposed revision of the TEN-E and its increased focus on sustainability, in addition to the principles of market integration and security of supply. We are also pleased with the creation of a hydrogen category which will help roll-out new infrastructure for hydrogen, with the inclusion of the smart gas grid category, electrolysers and the general recognition to the role of renewable gases.
However, as showcased by the IEA1 and by nearly all European Commission ‘net-zero by 2050’ scenarios2, the EU will need CCU and CCS to succeed on climate. It is therefore of utmost importance that their entire value chain, from capture to multi-modal transport and storage, is integrated into the revised TEN-E Regulation and associated funding instruments. For this reason, we welcome the recent positive developments both in the Council and in the European Parliament.
At present, in Europe there are around 50 commercial facilities in operation or at various stages of developments3 in Austria, 7 in Belgium, 3 in Croatia, 1 in Czech Republic, 1 in Denmark, 2 in France, 2 in Germany, 1 in Ireland, 1 in Italy, 1 in Romania, 1 in Spain, 2 in Sweden, 8 in The Netherlands). But more are required. With a strong political support from the EU and its Member States and the required European legal framework, CCS and CCU can be scaled up in Europe. This will significantly contribute to the reduction of the most difficult GHG emissions, will aid industrial competitiveness, and will create much needed opportunities for growth and keep industrial jobs and related research & innovation in Europe in the post-pandemic recovery phase.
In the context of the on-going inter-institutional negotiations, we call on your support to ensure that the Council’s text of the revised TEN-E Regulation4 safeguards the following key amendments to the Commission’s proposal:
Inclusion of CO2 storage in the scope of the Regulation
CCS and CCU are effective climate-mitigation tools. In this context, CO2 storage has a cross-border dimension, giving options to industry to reduce emissions through CCS also in those Member States where storage is not available, or who do not wish to store CO2 locally. CCS will equally be critical to scale up the hydrogen market, by enabling the large-scale production of low-carbon hydrogen. To maximise the potential for success, CCS should be developed on a full value chain basis.
Failing to ensure that CO2 storage benefits from the provisions of TEN-E, would send a negative investment signal and make integrated planning very difficult, not least for financing reasons. It will, quite simply, jeopardize Europe’s ability to reach its ambitions on decarbonising the industrial sectors5 and on including the production of low-carbon hydrogen.
Inclusion of all transport modalities of CO2
A number of planned CCS projects in Europe aim to transport CO2 from one country to another for storage, by pipeline or other modes of transport such as by ship, rail or truck. A flexible approach to the transport of CO2 will be needed depending on national circumstances. The ‘pipeline-only’ approach currently proposed by the Commission would in effect discriminate against Member States or regions that have limited CO2 storage requirements, without access to CO2 pipelines, but may be proximate to inland waterways or coastal infrastructure or those who do not wish to store CO2 locally. Such activities will take place in hubs and clusters where different industries will share infrastructure for transport and storage, allowing for economies of scale through a cross-sectorial and cross-border industrial system.
The TEN-E is the ideal framework for trans-border projects and will foster the creation of a much-needed multimodal CO2 transport network across Europe.
Hydrogen-ready and repurposed gas pipelines at Distribution system operator (DSO) and Transmission System Operator (TSO) level to be included in the energy infrastructure category at least for a transitional period
From a 2050 perspective, alongside new hydrogen-ready projects, the adaptation of existing EU gas infrastructure (repurposing and retrofitting), at both DSO and TSO level, to carry a growing share of hydrogen across Europe through blending, will be key to enable a cost-effective transition. Low-carbon hydrogen will make up for a significant share of hydrogen in Europe6 in coming decades – it is important that the future policy framework, and in this case the TEN-E Regulation, enables the growth of both renewable and low-carbon hydrogen.
The purpose of Better Regulation7 is to ensure that EU legislation makes a concrete and positive contribution to the lives of its citizens, facilitating the development of businesses and helping them face current and future challenges. A technology-inclusive revision of the TEN-E Regulation can exemplify this reinforced approach to better European law-making.
Signatories
- GasNaturally
- IOGP (International Association of Oil and Gas Producers)
- Eurogas
- BVEG (German Association for Natural Gas, Crude Oil and Geoenergy)
- GIE (Gas Infrastructure Europe)
- GERG (The European Gas Research Group)
- NHO (Confederation of Norwegian Enterprise)
- NOGEPA (Netherlands Oil and Gas Exploration and Production Association)
- NOROG (Norwegian Oil and Gas Association)
- OGUK (Oil & Gas UK)
- International Energy Agency (2020), Energy Technology Perspectives
- JRC report ( 2020) ‘Towards net-zero emissions in the EU energy system by 2050’
- IOGP Map of CCUS projects in Europe
- Council’s position at first reading
- https://www.europeanfiles.eu/climate/large-scale-decarbonisation-solutions-for-a-climate-neutral-industry-and-jobs-in-europe
- Hydrogen4EU study
- https://ec.europa.eu/info/sites/default/files/better_regulation_joining_forces_to_make_better_laws_en_0.pdf
- Publications
- Letters to Officials
- Events

Response to the European Commission’s consultation on the draft Clean Industrial Deal State Aid Framework (CISAF)

Joint statement on the role of LNG in Europe’s energy transition

Response to the Draft Delegated Regulation on CO₂ Injection Capacity Obligations

Public consultation on inter-temporal cost allocation mechanisms (ICA) for financing hydrogen infrastructure

IOGP Europe views on Communication on the Action Plan for Affordable Energy

Advancing a Competitive, Resilient, and Integrated Energy Market

IOGP Europe Response to the Consultation on the Review of the Taxonomy Climate Delegated Act

Joint Statement: Reality Check for European Hydrogen Policy to Adjust the Course

The Case for a European CCS Bank

The Joint Statement on the Low-Carbon Fuels certification draft Delegated Act

IOGP response to the public consultation on the draft Methodology to determine the greenhouse gas (GHG) emission savings of low-carbon fuels

Joint EGEC-IOGP Europe recommendations: Accelerating the deployment of Geothermal in Europe

IOGP Europe key principles on a future regulatory framework for CO2 transport infrastructure

Joint Statement – Harnessing the IPCEI mechanism for CCS in Europe

Joint Statement on the Low-Carbon Fuels certification Delegated Act

GasNaturally Letter to Competitiveness Council 23 May 2024

IOGP Europe recommendations on the Delegated Act specifying a methodology for assessing GHG emissions savings from low-carbon fuels and low-carbon hydrogen

Rebalancing Europe’s Gas Supply Second Edition

IOGP consultation response: Rationalisation of reporting requirements

Creating a sustainable business case for CCS value chains

Map of CO2 storage Projects in Europe

IOGP Europe statement on the ECHA proposed PFAS restriction proposal related to the Carbon Capture, Transport and Storage (CCS) Technology

IOGP Europe position on the EU Industrial Carbon Management

IOGP position paper on the European Commission’s public consultation on the EU climate target for 2040

IOGP Europe feedback on Net Zero Industry Act proposal

Joint industry statement on the EU Taxonomy

IOGP response on Competitive Bidding schemes for hydrogen under the Innovation Fund

IOGP response on revamping the Strategic Energy Technology (SET) Plan

IOGP views on the proposed Regulation amending Regulation (EU) 2021/241 as regards REPowerEU chapters in Recovery and Resilience Plans

IOGP response to the consultation on certification of carbon removals – EU rules

IOGP response to the public consultation on the Hydrogen and Decarbonized Gas Market package

IOGP comments to R. W. Howarth and M. Z. Jacobson (2021): How Green is Blue Hydrogen?

Re-Stream – Study on the reuse of oil and gas infrastructure for hydrogen and CCS in Europe

IOGP response to the public consultation on the Energy Taxation Directive (ETD) proposal

IOGP response to the public consultation on the Renewable Energy Directive (RED) proposal

IOGP feedback to the European Commission’s Roadmap on restoring sustainable carbon cycles

IOGP response to the public consultation on the Carbon Border Adjustment Mechanism (CBAM) proposal

IOGP position on the revision of the EU Emissions Trading System (EU ETS) Directive

IOGP response to the public consultation on the Energy Efficiency Directive (EED) proposal

IOGP response to the public consultation on the FuelEU Maritime proposal

IOGP response to public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)

IOGP Paper on metric to use for 2030 targets

IOGP input to the consultation on the Hydrogen and Gas Market Decarbonization Package

IOGP response to the roadmap on the modification of the General Block Exemption Regulation (GBER)

Public consultation on the EU Action Plan “Towards a Zero Pollution Ambition for air, water and soil”

Response to consultation on updating the EU Emissions Trading System

IOGP response to consultation on the revision of the Guidelines on State aid for environmental protection and energy (EEAG)

IOGP response to the Inception Impact Assessment on the revision of the Guidelines on State aid for environmental protection and energy (EEAG) 2014-2020

IOGP views on competition policy supporting the European Green Deal

IOGP statement on the European Commission’s 2030 Climate Target Plan

What’s Right? What’s Wrong? IOGP comments on the ‘EU Strategy for Energy System Integration’ and ‘A hydrogen strategy for a climate neutral Europe’

IOGP written input to the public consultation on the Carbon Border Adjustment Mechanism (CBAM)

IOGP views on State aid for environmental protection and energy (EEAG)

IOGP written input to the consultation “2030 Climate Target Plan”

IOGP response to the inception impact assessment concerning the revision of the 2018 Renewable Energy Directive (REDII)

IOGP feedback on the update of EU ETS monitoring and reporting rules (2021-30)

IOGP response to supplementary questions on the EIB Group’s Climate Bank Roadmap 2021-2025

IOGP response to consultation on the renewed Sustainable Finance strategy

Funding CCS in Europe: key investments for the recovery

IOGP response to the public consultation on the revision of Regulation (EU) 347/2013 on guidelines for TEN-E Regulation

IOGP response to targeted consultation on the revision of Regulation (EU) 347/2013 on guidelines for TEN-E Regulation

IOGP input to the Roadmap on the EU Smart System Integration

IOGP input to the Roadmap on the EU strategy on hydrogen in Europe

IOGP feedback to the Combined Evaluation Roadmap/Inception Impact Assessment on the revision of Regulation (EU) 347/2013 on guidelines for TEN-E

IOGP feedback to the roadmap for a Renovation Wave initiative for public and private buildings

IOGP input to the forthcoming EU Strategy for Energy System Integration

IOGP response to the EIB Group’s Climate Bank Roadmap 2021-2025

Input to the inception impact assessment on the FuelEU Maritime

IOGP feedback to the proposed European Climate Law

Feedback to the impact inception assessment “2030 Climate Target Plan”

New and old CCS projects in Europe: What’s different this time?

IOGP assessment of National Energy and Climate Plans

Methane Management in the Upstream Oil and Gas Industry: Policy recommendations in the context of the EU Methane Strategy

Scaling up Hydrogen in Europe

Hydrogen for Europe Pre-study – Key findings

IOGP assessment of draft National Energy and Climate Plans

Hydrogen for Europe

The potential for CCS and CCU in Europe Report to the thirty second meeting of the European Gas Regulatory Forum 5-6 June 2019

LNG – a fast lane to make Europe a leader in clean shipping

CCS: the Innovation Fund and beyond

OGP contribution to the CCS Directive evaluation

Letter: IOGP Europe recommendations on the Hydrogen and Decarbonized Gas Market Package

Letter: Industry views regarding the proposal to establish a permanent demand aggregation and joint purchasing mechanism through the Recast Gas Regulation

Letter: Strong support for an implementable and pragmatic Net Zero Industry Act Article 18 – solutions to make CCS work

Letter: Open, inclusive, and pragmatic Green Deal Industrial Plan for Europe

Letter: IOGP input on the European Commission’s consultation on the priority list for the development of gas network codes and guidelines for 2021 (and beyond)

Letter: 57 industry leaders call for enhancing gas contribution to decarbonisation

Wide industry coalition call for a Hydrogen Strategy inclusive of all clean hydrogen pathways

Joint letter: CCS and CCU for the EU’s Industrial Transition

Partnership with the Carbon Capture Global Summit 2025

IOGP Europe at EuropEC 2025

IOGP Europe at the CCSA EU Conference 2025

IOGP Europe at the 2025 Flame Conference

CCS policy: A practical toolkit

2024 CCSA EU Conference – 3rd July

SPE Europe Energy Conference

CCS Strategy Europe Conference

Rebalancing Europe’s natural gas supplies – Learnings, future needs, and policy implications

Creating a sustainable business case for European CCS value chains

Scaling up the energy transition whilst securing a stable suppy

The Europe CCUS & Hydrogen Decarbonisation Summit

Re-Stream Study Launch Event

Hydrogen4EU Launch Event

Sustainable finance: investor, oil and gas sector and global perspectives

Carbon Management Webinars

Sustainable finance: non-financial disclosure for the oil and gas sector and EU taxonomy in practice
