In the midst of an energy crisis very much resulting from Europe’s high dependence on fossils, the European Commission’s proposal for a package set to decarbonise our gas markets fails to free Europe from fossil lock-in – with long-term contracts for unabated fossil gas only seeing stop to extension by 2049. 

 The newly published rules take an important step in the right direction by making it comparably easier for renewable and low-carbon gases to access existing gas grids with reduced tariffs and proposed definitions and certifications for low-carbon fuels. While Bellona Europa commends the much-needed inclusion of definitions for both “low-carbon hydrogen”, “low-carbon gas” and “low-carbon fuels” in the revised Gas Directive 2009/73/EC, we add that clearer language on scope is needed when determining their climate impact. These clarified definitions also must be added both to the Gas Directive and Regulation. 

Despite the package’s reliance on decarbonised fuels on the path to net-zero by 2050, it fails to recognise the importance of the very infrastructure key to enable the production of these fuels: CO2 transport and storage networks. The lack of any mention of CO2 infrastructure’s key role in the published proposal of the Gas Regulation, setting the conditions for access to the gas transmission networks, risks the package becoming a missed opportunity to facilitate this infrastructure of the future.   

The proposal is also jeopardised as definitions of renewable and low-carbon fuels are lacking detail, both within the Gas Package and beyond the directive and regulation. The failure of the European Commission to publish the RED delegated acts on RFNBOs and recycled carbon fuels leaves the entire decarbonisation of gas without clear criteria to be built on. While the EU is discussing increasingly high targets for these fuels, the lack of a framework that ensures their carbon footprint is close to zero hinders any climate benefit they might bring.  

Finally, the Gas Regulation and Directive do not address one of the most critical issues in the development of a decarbonised gas market: the use of such gases. Low-carbon and renewable gases will remain a very limited feedstock and their use should be targeted at those sectors which cannot otherwise decarbonise. Proposing a 5% cap for blended hydrogen in the natural gas network incentivise blending over dedicated infrastructure. This goes against targeted use where a pure feedstock is needed, like in the steel, chemicals and fertilizer industry.