Commissione Europea - Osservazioni di Elettricità Futura alla Combined Evaluation/Inception Impact Assessment - Ares(2021)1159348 sulla proposta di revisione delle norme dell'UE in materia di accesso al mercato (Proposta di regolamento)
Elettricità Futura welcomes the development of a Hydrogen and Gas markets Decarbonisation Package. Direct electrification is a viable and efficient solution to decarbonize a large part of the energy demand, while hydrogen can play a significant role in specific hard to abate sectors. Other green gases and biofuels can also be part of a decarbonized energy mix. Likewise, the new EU gas package should define a legal and regulatory framework that caters for the emergence of a European hydrogen market grounded on a shared understanding of its technological, industrial and economic context. Following a gradual approach, the EU strategy for hydrogen can ensure level playing field and competition as a compass and envisage a "preparatory phase" that focuses on research, pilot projects and regulatory sandboxes. As other gas intensive industries, the paper one is efficiency oriented, equipped with CHP systems and ready to integrate some hydrogen (5-10%). To this regard we remark that an inclusive energy transition must safeguard assets’ value as well as competitiveness of virtuous industrial consumers. Considering hydrogen production costs, availability and decarbonization potential, it should be first considered to foster green hydrogen production at or near the site of use. Whereas injecting hydrogen into natural gas networks could stimulate a market off-take, such application results less efficient than others, more focussed on hard to abate sectors. In addition, while hydrogen and synthetic gases will need time to disclose their potential, biomethane can offer, in some circumstances, an immediate alternative to natural gas. Once established a system of guarantees of origin, virtual PPA-gas could allow the virtual transaction of significant amount of clean gas. Renewable and low carbon gases should be qualified depending on production process and associated GHG emissions. The imported gas should also be included in a suitable classification, mirroring the import of renewable electricity. Network planning should be carried out in a cross-sectoral perspective and based on cost-benefit analysis, pursuing the realization of a sustainable and efficient infrastructure at the minimum social cost. The regulatory framework should build on the key principles of unbundling, third party access and independent authorities should refer to them to correctly evaluate the development plans. Regarding the development of gas distribution and transport networks, sustainability criteria should be enforced, according to the proposal for TEN-E regulation, while the Energy Efficiency first principle should lead any project.