Consultation on proposed revision to the Gas Directive and the Gas Regulation and proposals for a Regulation on Methane Emissions

Friends of the Earth Ireland submission

The central message of this submission is that unless significant changes are made to the Commission’s proposals on the Gas Package, this crucial piece of legislation risks creating further fossil gas lock-in, endangering Ireland & the EU’s climate and energy targets, and will fail to resolve the conflicts of interest established in the current legislation. Additionally, the gas package in its current form does not address the effects of the current energy crisis, and risks further exacerbating energy poverty.

The current proposal fails to provide the much broader framework to reduce fossil gas consumption across the EU by 2030 significantly and reach a complete phase-out of fossil gas by 2035 at the latest.

 Friends of the Earth’s submission sets out recommendations on how the gas package must contribute to emission reductions in line with the Paris Agreement though preparing gas distribution networks for change; improving governance to remove conflicts of interests in network planning; addressing hydrogen use and blending; and protecting energy communities

 Key Recommendations:

● Enable Distribution System Operators (DSOs) to prepare for decommissioning. Include explicit transparency obligations for DSOs in the context of energy infrastructure planning and ensure network plans are in line with EU and national climate and energy targets.

● Improve governance to remove conflicts of interest in gas network planning and guarantee a complete separation between the ownership, control, and operation of fossil gas and hydrogen assets.

● Exclude hydrogen blending to enable a targeted use of hydrogen, and ban connection to newly built (or repurposed) hydrogen distribution grids to users that are not identified as priority users.

● To be fit for purpose, the gas package should drop its framing of a one-to-one replacement of fossil gas with renewable and low carbon gases. It instead should focus on putting in place tools that enable the scaling down of gas use in the market and on using hydrogen only for the most strategic applications.

● Exclude any reference to “low carbon hydrogen” in the Directive. Include biogas produced exclusively from waste and residue feedstocks, and define clear sustainability standards for biogas production.

● Protect the integrity of Energy Communities by deleting all references to “gas energy communities”