IOGP response to the roadmap and inception impact assessment concerning revision of the 3rd Gas Package

This document provides IOGP’s response to the EU roadmap and inception impact assessment on the revision of the 3rd Gas Package (Directive 2009/73/EC and Regulation No 715/2009).

Context

This initiative proposes to revise EU gas rules to facilitate the market entry of renewable and low-carbon gases and remove any undue regulatory barriers.

Key Points

IOGP recommends that the impact assessment considers the following as the basis for its amendment consideration:

• Ensure that the regulatory framework for decarbonisation of the gas sector builds on the achievements of the Internal Gas Market
• Enable gas-infrastructure-operators to develop and operate gas pipeline infrastructure for hydrogen and CO2 matching the gas sector key network regulatory requirements
• Accommodate renewable and low-carbon gases in a technology neutral manner under the gas market rules
• Establish a credible, robust and manageable certification scheme based on voluntary guarantees of origin under RED II to valuing life cycle GHG intensity reduction of renewable and low-carbon gases
• Enable a competitive hydrogen commodity market irrespective of origin
• Strengthen consumer rights that mirror electricity market design
• Avoid undue gas quality restrictions at system entry points
• Recognise that for many applications electrification does not provide the best solution or a resilient energy system
• Ensure holistic infrastructure planning
• Recognise the significant role of TSOs and DSOs cooperation to take full advantage of opportunities to decarbonise gas sector
• Recognise the role that CCUS can play in reducing GHG emissions