CATF Statement on the European Commission’s TEN-E Revision

Today, the European Commission released its revision of the Trans-European energy infrastructure regulation, otherwise known as the TEN-E regulation. The Clean Air Task Force (CATF), a climate and energy research and advocacy organization with offices in the US and Europe, applauds the Commission’s progress on this regulation.

CATF supports the European Commission for its climate ambition, leadership on decarbonization and innovation, and pursuit of policies to decouple greenhouse gas emissions from economic growth. CATF also strongly supports the EU’s ambition to become climate neutral by 2050 and welcomes the revision of the TEN-E regulation to support compatibility with the EU’s climate ambition.

In July 2020, CATF submitted an official response to the proposed TEN-E regulation. The headline suggestion was to focus on enabling the expansion of infrastructure necessary for carbon neutrality and regard infrastructure as a key multiplier in the transition to a climate-neutral economy.

The TEN-E revision reflects welcome updates on two priorities that CATF focused on in its response: carbon dioxide transportation and clean hydrogen transport. These changes are a positive step, but there remain further details which CATF suggests revisiting in order to make the final regulation as robust as possible.

“The continued inclusion of carbon dioxide transport as a priority thematic area is a positive step,” said Lee Beck, CCUS Policy Innovation Director. “However, we need to urgently take further steps to improve the policy and regulatory framework enabling carbon capture, removal, and storage projects as laid out in CATF’s recommendation for the Revision of TEN-E. Particularly geologic storage of CO2 will be crucial to industrial decarbonization and to deliver negative emissions, and should thus be included in the regulation.”

Specifically, CATF would like to draw attention to the following:

• Reflect and include the full range of CO2 transportation modalities such as pipelines, ships, truck and train as well as connecting and/or docking facilities, allowing all European regions and industries to connect. This would allow for flexibility of siting and application diversifying the risk of just relying on a single mode of transportation.
• Regulate non-discriminatory third-party and open access to CO2 transportation networks and storage.
• Include the full infrastructure value chain of carbon capture and storage including geologic storage of CO2 along with CO2 transportation networks. While CO2 utilisation is an option, geologic storage needs to be developed at scale for CCS to scale and limit the overall cost of decarbonization.
• Include the retrofitting of pipelines for CO2 transport.

“The inclusion of hydrogen infrastructure in the scope of the TEN-E framework is important for decarbonization progress in Europe,” said Mike Fowler, Director of Advanced Energy Technology Research.

As CATF noted in July, the TEN-E regulation also needs to recognize the critical role that hydrogen-related infrastructure development will play in achieving the EU’s decarbonization objectives for 2030 and 2050, including climate neutrality under the European Green Deal, by supporting both the supply of and demand for low- and zero-carbon hydrogen across multiple sectors of the EU and global economy.

CATF looks forward to working with the Commission on these points in 2021 ahead of adoption of this regulation.