FNB Gas statement on EU methane legislation

The Association of German Transmission System Operators and its members support the recommendation paper of ENTSOG, Eurogas, GERG, GIE, MARCOGAZ on the proposals of the European Commission on the reduction of methane emissions in the energy sector. In addition, the present statement adds some partly technical notes to the draft regulation.

According to the DVGW, the share of methane emissions from the oil and gas industry (including extraction) in Germany-wide GHG emissions is 0.5 %. Grid operators have significantly reduced their methane emissions since 1990 thanks to the implementation of various emission reduction measures. German transmission system operators are determined to continue and intensify their contribution to reducing emissions.

We understand the need for a regulatory framework to reduce methane emissions and welcome the European Commission’s proposal. FNB will support the implementation of an appropriate and cost-effective action plan.

In recent years, a number of reports have been produced by the gas industry at the national and international levels highlighting the actions taken by gas system operators to reduce their methane emissions. The documents contain up-to-date data, facts and figures as well as concrete definitions and demonstrate the industry’s commitment to the path to climate neutrality.

To accelerate the transition process to carbon neutrality, it is critical to develop an abatement plan based on updated data. This will ensure that the transformation process is as effective and sustainable as possible.

The most important principles for a successful approach

1. Maintain proportionality: Measures must not result in the imposition of costly measures on gas consumers that have little or no mitigation effect.
2. Differentiated approach: not all measures to avoid methane emissions are equally suitable for all parts of the gas value chain (production, extraction, transport, storage, distribution, LNG). Fundamental flexibility is needed to prioritize actions and ensure that the optimal, cost-effective approach to mitigation is applied.
3. Introduction of a transparent and robust MRV system (monitoring, reporting, validation): To enable consistent reporting and proper monitoring of reduction programs and measures, an MRV system aligned with the demanding OGMP 2.0 reporting standard should be implemented at the European level (applying the reporting framework, technical guidance documents and relevant concepts, definitions and requirements, such as materiality, representative sampling, etc. of the OGMP 2.0 program)