Position paper on the European Commission’s Proposal for a Methane Emissions Regulation

The Russian invasion of Ukraine has initiated discussions on the overall EU’s energy strategy, demonstrating the need to accelerate decarbonisation efforts, especially the deployment of renewables such as renewable and low-carbon gases, including hydrogen. In the transition phase, natural gas will keep playing an important bridging role, as it is deeply established in many Member States.

Methane’s global warming potential is estimated to be at least 25 times that of carbon dioxide over a 100-year horizon and even greater on a 20-year horizon. Identifying, quantifying, and minimising sources of methane emissions across the energy industry is therefore crucial.

In light of this, we welcome the publication by the European Commission of the ‘Hydrogen and Decarbonised Gas Market’ legislative package on 15 December 2021, which aims to tackle methane emissions in the energy sector with a new proposal for a Methane Emissions Regulation.

Executive summary

1. Identifying, quantifying, and minimising sources of methane emissions across the energy industry is crucial to meet the objective of climate neutrality by 2050. The introduction of a dedicated EU Methane Emissions Regulation will significantly contribute to the mitigation of methane emissions at EU level but also globally.
2. Proportionality is key when tackling methane emissions as a small amount of infrastructures and events are responsible for the overwhelming majority of methane emissions.
3. The Methane Emissions Regulation should refer to existing technologies, practices and standards insofar as possible, including the Oil and Gas Methane Partnership (OGMP) 2.0.
4. Sufficient time should be foreseen to enable operators, importers, verifiers and authorities to fulfil their requirements under this Regulation.
5. A doubling of reporting efforts should always be prevented. Yearly methane emission reports mentioned in article 12 should also cover results of LDAR surveys and venting and flaring events to limit the administrative burden for both operators and authorities.
6. A requirement to perform a yearly LDAR programme should be prescribed. Operators and authorities could then agree on increasing the frequency of LDAR surveys for specifically identified components, based on a number of factors including seasonality, previous experiences and assessments of leak intensity. A requirement to repair all detected leaks in a reasonable timeframe should be introduced.
7. Venting and flaring events should be limited to the extent possible. However, they cannot be eliminated completely due to safety reasons. The ban on routine flaring and requirement to avoid venting should therefore be supported, provided that exemptions are foreseen in case of emergency and when unavoidable and strictly necessary.
8. Methane emissions are a global issue. The creation of a Global Methane Monitoring tool and the strengthening of the International Methane Emissions Observatory (IMEO) are therefore positive. Importers to the EU play an important role in raising awareness on methane emissions. However, their liability should be limited to the provision of information they can effectively collect, such as the name of exporter.

Read the whole paper (pdf)