Renewable Energy Directive

RED II Implementing Rules for voluntary schemes – Union Database

Position paper on the revision of the Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (RED)

Feedback on the EU Renewable Energy Directive (REDII)

Feedback reference F2751232
Submitted on 10 November 2021
Submitted by Mariam ED-DBALI
User type Business association
Organisation Gas Distributors for Sustainability
Organisation size Large (250 or more)
Transparency register number 382692732615-35
Country of origin Belgium
Initiative EU renewable energy rules – review

GD4S welcomes the ongoing revision of the Renewable Energy Directive (REDII). The publication of the Energy System Integration and Hydrogen strategies has underlined the importance of renewable gases in achieving carbon neutrality in a cost-efficient way. The revision of REDII is the legislative opportunity to stimulate their development.

GD4S supports the overall level of ambition proposed for sectoral targets (transport, building, industry). However, targets should also focus on decarbonising the current energy vectors. A binding renewable gas target at the EU level as a percentage of the total gas consumption would ensure effective decarbonisation of the gas sector by supporting increasing production and grid injection. The market can find the optimum allocation of end uses once a technology agnostic market is established. Achieving GHG emission reduction targets must be done in a resilient way, by investing in the energy mix that will provide continuous and secure supply to meet all needs.

Injecting renewable energy in the gas grid is an efficient and effective way to reach the renewable energy objectives of the Union with the least impact on consumers. Demonstrating the sustainability and origins of a product is essential to user acceptance. GD4S would point out that the scope of Guarantees of Origins (GO) under Article 19 could be extended to trace sustainability, in addition to origins of the fuel. Moreover, GO mechanism should be fully in line with EU ETS mechanism in terms of monitoring and reporting. This would help to create a more liquid market for renewable gases, based on the sustainability of the product. Whilst GD4S welcomes the intent of the European Commission (EC) for the Union Database, it is important to avoid excessive administrative burdens, resulting in a lower uptake by consumers or higher cost product. Existing GO systems are already in place, favoured by the market and could be modified to deliver the same outcome.

It should be emphasized that heating and cooling (H&C) systems and equipment are not “renewable” or “fossil” by themselves. The energy used to supply them determines the renewable label of the product. As such, it is important to maximise the use of renewable energy within H&C systems, in addition to efficiency upgrades. To this end, provisions within REDII should better promote the supply of renewables in buildings as a means of meeting the proposed 49% target for the sector. Administrative requirements to certify and track the fuel use via GO should be promoted as an effective way to achieve this.

The recent proposal of the EC on the delegated act for the Union Database and the certification schemes showed some clarifications should be written about the mass balance approach: as such, the interconnected European gas grid should be considered as a unique system, and the last consignment of the mass balance calculation should be at the injection point for all renewable gaseous fuels injected into the gas grid.

Under Article 27, the use of additionality criteria for RFNBOs could limit the amount of fuel produced from grid connected electrolysers. This is not consistent with sector coupling and GD4S would urge the EC to take a pragmatic approach in this area, unlocking investment and supporting EU ambition. The revision of REDII is also the opportunity to maximise the potential of sustainably produced biomethane and to recognise its environmental benefits. Annex IX, listing feedstocks that can be used for biogas production, should be revised to broaden the scope of feedstocks able to be used. For example, all biowastes according to the definition in the Waste Directive (2018/851) shall be included. A category for intermediary crops (or cover/catch crops) should be included as they provide numerous environmental benefits.

GD4S remains at the disposal of the EC’s services for any clarifications, looking forward the next steps of the consultation process.

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