Confindustria welcomes the revision of Directive 2009/73 and Regulation 715/2009, considering that the future H2 framework can be embedded within the principles of the Gas Internal Energy Market.
Gas is an enabler of the EU decarbonization: several sectors rely on natural gas to fuel industrial processes (directly or through cogeneration) or as input for chemical production. Moreover, in many EU countries power generation from natural gas is going to be the main technology replacing coal and granting flexibility for NPRES in the medium term. Finally, gaseous fuels can contribute to the transport sector low carbon transition, especially in maritime, heavy duty and aviation sections. Therefore, an integrated gas system, including LNG, plays a crucial role for European Supply, energy diversification and market competitiveness. There is still to be done to achieve the Gas Target Model objectives and spreads among markets are still critical between North-West Europe and the Italian hub because of transportation tariffs along gas routes (pancaking effect). Different solutions could be effective to obtain a single gas market, e.g. the merge of national entry/exit zones applicating tariffs on external borders and on demand. It can also prevent the risk of decommissioning for those pipelines currently facing low demand but necessary for market competition and future H2 repurpose. Nevertheless, provisions aimed to enhance competitiveness should be fully applied and the 15-year time limit for LT capacity should be voluntarily applicable to existing contracts deriving from past allocation procedures.
The deployment of low/zero carbon gaseous fuels will provide a contribution in lowering the GHG emissions if adequate amounts of commodity, interoperable grids, secure storage equipment and reliable end-use technologies would be available at competitive prices to fulfill energy consumption of hard to abate sectors, in synergy with electrification trends. To reach the Green Deal objectives it is important to create a coherent legislative framework, combining all EU Regulations, so to define policies and market-based mechanisms to facilitate new gasses demand, vectoring, generation and value chain equipment production (It’s for example crucial the reduction of administrative barriers). A fair competition among technologies (P2X, storage, CCS/U etc..) and vectors shall be promoted, through the institution of an EU classification / certification, based on life cycle GHG emission savings, and a level playing field for all flexibility and market resources. It is important to pursue a gradual, flexible, open and technology neutral approach: the early development of alternative gasses shall avoid distortions of the NG markets and tariffs and be coordinated with the effective starting point/production possibilities of the different UE Countries. A regulatory sandbox approach would be beneficial to encourage R&D projects and subsidies should be considered to ease the decarbonization of those sectors where electrification is not technically or economically feasible besides where a H2 use/infrastructure already is present.
In view of a growing electricity-gas sectors coupling and market integration, the key principles of the energy regulation (e.g. unbundling, TPA) and cost-benefit evaluations of the infrastructure planning shall be synergically considered. The EU legislation should recognize the possibility for TSOs/DSOs to own, develop and operate H2 networks, as well as, to test H2 injection into their grids, so to verify standards (safety, quality, measurement) and promote the efficient use and retrofitting/repurposing of existing infrastructures, avoiding stranded costs. It’s important to ensure a transparent, fair and non-discriminatory access to the infrastructure to the decentralized production of renewable and low carbon gases and hydrogen and a correct allocation of costs avoiding cross subsidies between regulated and market-based activities.
Posizione Confindustria - Consultazione Hydrogen and Gas Market Decarbonization Package.pdf|Visualizza dettagli
