Eurogas welcomes the new Renewable Directive proposals as a timely and necessary recast of the legal framework for renewable energy in Europe. We support the definition of a future market outset able to produce undistorted and competitive price signals, encourage adequate investment levels, guarantee the security of the energy system, and proceed on the decarbonisation path towards the EU objectives to 2030 and the Paris Agreement - all this without affecting the competitive nature of the offers to consumers.

The growth in the deployment of renewables in the form of variable electricity production has been up until today a partial solution to reach the 2020 EU target, while its challenges become more important as an even more ambitious renewables target is pursued to 2030. Those challenges include ensuring that the future energy system continues to be technically reliable and sustainable from an environmental and economic point of view. It is therefore essential for European policy makers and stakeholders to make it a priority that the deployment of variable renewable energy is coupled with reliable and flexible generation and energy storage so as to adequately account for the stresses on the system and the burdens on the consumers. It has been estimated that if we are to achieve upwards of 80% carbon reductions with the technology currently available, Europe will need 10 times the amount of storage it has today.¹ Batteries alone, however, cannot cope with this challenge, especially considering seasonal variability² , due to limitations with regard to quantity and duration of electricity storage (toxicity and resource limitations are other concerns), not to mention the cost dimension. Energy storage is, and will continue to be, a crucial element in energy policy, and gas stands ready to provide the needed storage.

While electrons cannot be stored in wires, molecules of gas are easily stored in pipes. Further, those electrons can be converted to molecules in a process of what is referred to as power-to-gas. Those molecules can also be converted to electrons via various gas-to-power technologies (combined heat and power (CHP), micro-CHP, fuel cells, dual-fuelled appliances, etc.). Gas can come from an array of sources, from the traditional natural gas to the renewable forms, such as biogas, bio-methane, synthetic gas, and hydrogen.

The gas grids then become reservoirs of sustainable energy for intake and throughput in a continuous, flexible manner, able to handle short and long-term intervals (for daily and seasonal variations), as well as geographic transfer. These technical characteristics must be borne in mind when considering legislation that undergirds renewable energy deployment. Gaseous energy becomes a basis for sector coupling in a sustainable energy system. Taking these technologies into consideration in a holistic way, it is clear that gas is needed not just as a flexible and reliable supporter, but as an integral part of the transition towards a decarbonised energy system where the renewable energy deployment happens within a diversified and sustainable energy mix.

Moving forward, the electricity, heat, gas, transport and information and communication technology (ICT) networks will become increasingly integrated to form a more seamless system in which energy can flow freely in whatever vector is best suited for a given moment, in consideration of varying supply and demand. The different vectors provide complementarity for the system, which is key both in terms of cost and convenience for the consumer, as well as technical feasibility and reliability of the system.

Eurogas welcomes the recast of the Renewable Energy Directive as a timely occasion to recognise these opportunities. With the role of gaseous energy in a future energy mix fully taken on board, the Renewable Energy Directive can shape the evolution of the energy system in such a way that consumer costs are minimised, energy security is maximised, and sustainability is realised.

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