ZEP responded to the consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG), highlighting that the guidelines need to be updated and aligned with the market developments and the more ambitious new climate agenda, the European Green Deal, the European Climate Law for climate neutrality by 2050, the EU Taxonomy for Sustainable Finance and linked initiatives.
ZEP responded to the consultation on the list of candidate Projects of Common Interest in cross-border carbon dioxide transport networks highlighting that securing political support for the list of candidate projects on cross-border CO2 infrastructure is vital. These projects are on the right track to become operational before 2025.
The revision of Regulation 715/2009 on the conditions for access to the natural gas transmission networks, provides an opportunity to expand relevant elements of the existing gas regulatory framework to accommodate the infrastructure networks of the future, as well as the transportation of new gases, including CO2 in the context of CCS. New open-access CO2 networks that capture and integrate the emissions from industrial sectors and installations can help to further promote energy systems integration, creating more optimised and integrated EU energy infrastructure. Repurposing existing natural gas infrastructure should also be discussed when revising the regulation in order to evaluate their potential for CO2 transport.
ZEP comments on the European Taxonomy for Sustainable Finance adopted delegated act.
Since the establishment of the technical expert group on sustainable finance (TEG), ZEP has provided advice to the TEG’s technical report and has given input and submitted consultation responses to the European Commission on the regulation on the delegated acts on climate change mitigation and adaptation.
ZEP responded to the Innovation Fund consultation on an amendment of the delegated regulation to enable a choice between a one-stage or two-stage application procedure for the next large-scale call. ZEP welcomes the European Commission’s consultation on the proposed changes to Innovation Fund application procedure. Confirming the input that was previously submitted, ZEP believes that the flexibility provided by the choice between a two-stage and a one-stage application procedure is interesting and appealing for applicants.
ZEP has responded to the consultation on the Inception Impact Assessment on Hydrogen and gas market decarbonisation package highlighting: Acknowledgment of CO2 within the scope of the legislation is key to kick-start Europe-wide CO2 infrastructure; With CO2 infrastructure put in place, volumes of low-carbon hydrogen from natural gas with CCS can be made available; Thorough, scientific carbon accounting must be at the basis of any regulatory framework that will support the use of renewable and low-carbon gases – including low-carbon hydrogen produced with CCS.
ZEP responded to the questionnaire on the review of the REDII Directive. ZEP highlighted that the REDII should be amended in order to be consistent with the objective of net-zero GHG emissions by 2050 and with other relevant pieces of legislation. Coordination among different pieces of legislation is critical to deliver a cost-efficient transition to higher 2030 targets, as well as to the objective of climate neutrality by 2050. There is an increasing role for low-carbon hydrogen to play to meet both 2030 and 2050 targets. CCS can play a crucial role in delivering early, large-scale volumes of low-carbon hydrogen from reformed natural gas, which will be needed to achieve the higher EU 2030 emissions reduction target.
ZEP responded to the EU ETS consultation highlighting that the revision of the EU ETS will need to be aligned with climate neutrality by 2050 and deliver on the increased 2030 ambitions. The revision of the EU ETS directive will bear several consequences for CCS and CCU projects. As geological storage sites are not evenly distributed among member states, the large-scale deployment of cross-border, European CO2 transport and storage infrastructure is crucial to reach the European Union’s objective of net-zero GHG emissions by 2050.