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)
IOGP welcomes the opportunity to respond to the European Commission’s proposed priority list regarding the development of gas network codes and guidelines for 2021 (and beyond). We agree that the development and implementation of gas network codes and guidelines is key to fully integrate the European internal gas market.
Gas network codes and guidelines on congestion management, capacity allocation, balancing, interoperability and data exchange, and transmission tariffs have already been adopted and are being implemented in Member States. The development and implementation of network codes and guidelines has required significant resources from all relevant parties including the Commission, ACER and ENTSOG, but certainly also from market participants. We believe that this was justified considering the positive market developments that have been achieved following implementation of the network codes.
In this context, the development of ‘new gases’ (such as biogas and hydrogen) can benefit from the common regulatory framework that supports the internal gas market. This framework provides security of gas supply as well as flexibility to deal with short-term fluctuations in supply and demand. We support ACER’s recommendation in their recent Market Monitoring Report that ‘decarbonisation efforts must go hand in hand with ensuring a well-functioning, fully integrated and competitive gas market. It is essential that clean transition does not lead to national market fragmentations’.
Annual priorities for 2021 (and beyond)
IOGP supports the Commission’s proposal not to include new items on the priority list for 2021 but to focus in 2021 on the implementation of the existing gas market rules in all Member States. According to ACER assessment on 2019, market integration is effective in area’s covering three-quarters of the EU gas consumption and advancing in the others. This indicates that no additional network codes are needed for an efficient functioning of the internal gas market. We also acknowledge that the Commission’s ongoing work on the revision of the Third Energy Package for gas in the context of the European Green Deal will require significant resources from all relevant parties in 2021 (and beyond).
In the previous consultation on the priority list for 2020 we mentioned that the considerations for a potential new electricity network code on cybersecurity apply to a large extent also to gas. Given that the Commission has decided on the need to develop a new electricity network code on cybersecurity in the period from 2020 to 2023, we suggest to consider – in due course – whether the electricity rules on cybersecurity warrant the development of a gas network code on cybersecurity.
We look forward to a continued dialogue with the European Commission, as well as with ACER and ENTSOG.
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Creating a sustainable business case for CCS value chains

Map of CO2 storage Projects in Europe

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?

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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”

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

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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

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: Call for a technology-inclusive revision of the TEN-E Regulation

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

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

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The Europe CCUS & Hydrogen Decarbonisation Summit

Re-Stream Study Launch Event

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Carbon Management Webinars

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