Consultation on the hydrogen and gas market decarbonisation package

ClientEarth's response to the European Commission's public consultation on the hydrogen and gas market decarbonisation package. This document contains our response to the consultation questionnaire, as well as some additional comments on how reforms should deliver the decarbonisation of gas.

ClientEarth's main position is that there needs to be a mandate for, and target to achieve, emissions reductions across the gas system in legislation (regardless of where that legislation sits). Within that target, there can be flexibility in paths for achieving it, but all decisions (planning, approvals, public funding, network codes and guidelines) should align with it. A clear decarbonisation mandate in the gas system would mitigate the risk that commitments of emissions neutrality from the gas industry will provide reassurance to decision-makers, but without legal effect. Such commitments could easily amount to greenwashing, and should not be relied on as they mislead the public and decision-makers.