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Saadetud: 16.03.2023 09:48
Adressaat: <"MKM info">
Teema: FW: Gas Package: NGO recommendations for the General Approach
Tähtsus: Kõrgeim
Manused: image002.png
From: Chiara Martinelli <
[email protected]>
Sent: Wednesday, March 15, 2023 5:08 PM
To: Kristel Tänover <
[email protected]>;
[email protected]
Cc: kristiina tammeraid <
[email protected]>; Esther Bollendorff
<
[email protected]>
Subject: Gas Package: NGO recommendations for the General Approach
Importance: High
Dear minister Sikkut,
Dear Ambassador Kokk,
Next week you will discuss the gas package and come to a final agreement on the legislative text.
In order to make it a genuine contributor to the EU’s Green Deal and REPowerEU objectives it
needs to be a driver for reducing EU gas consumption by 2030. The EU Climate Law projects a
35% reduction in gas demand whereas REPowerEU goes up to 52% by 2030 . Member
States should also clearly reject the uptake of low carbon energy under the renewable energy
directive.
The gas package must not be used to damage the Renewable Energy Directive
(RED): The gas directive still includes article 8a, which allows low carbon hydrogen to
count towards the industry and transport sub targets under the RED. Nuclear and fossil
based hydrogen are not renewable hydrogen and should under no condition be
included in the framework dedicated to the deployment of renewable energy. The
Council’s legal service has strongly advised against this approach and we, together with
a large industry and NGO led coalition are calling on Member States to reject article
8a.
Member States need to fill a political vacuum and adopt an ambitious definition for
low carbon gases: Today, the EU does not have a definition (as opposed to the US)
for low carbon gases. We welcome the improvements in recent Council discussions
regarding the inclusion of the fossil fuel comparator of 94 g CO2eq/MJ. However, for low
carbon gases to truly help decarbonize the gas sector, the definition still needs to
be strengthened and raised from 70% up to an 80% reduction against the above
mentioned fossil fuel comparator. An 80% threshold would allow for a full life cycle
approach including upstream emissions with strict requirements to mitigate methane
leakage and minimum carbon capture rates.
Preparing networks for the future: The goals of reducing dependency on gas imports –
in particular Russian supply – and tackling the fossil energy price crisis have a substantial
impact on the distribution system level (DSOs). Gas DSO’s future business model needs
to be much more integrated and locally steered. Civil society and municipality
organisations have called on giving more oversight to the regulators and helping
energy networks to prepare for more renewables, especially in the heating sector.
This will also support better planning of decommissioning of unused gas networks, in line
with phasing out EU gas consumption.
We trust you will share our view on the critical importance of improving the gas package before
adoption. We are happy to provide additional input if needed,
Yours sincerely,
Chiara Martinelli, Director, Climate Action Network Europe,
On behalf of:
Chiara Martinelli
Director
Climate Action Network (CAN) Europe
Rue d'Edimbourg 26 - 1050 Brussels - Belgium
Find us online at www.caneurope.org
and on Twitter at @CANEurope @MartinellChiara
M: 0032-489187055
E:
[email protected]