Brussels, February 2023 – ERGaR and Five Other Associations Send Joint Letter to European Commission Regarding Union Database
Together with the European Biogas Association (EBA), the European Federation of Energy Traders (EFET), Eurogas, ENTSO-G, and Gas Infrastructure Europe (GIE), a joint letter was sent to DG ENER of the European Commission to raise serious concerns on the operational design and launch planning of the Union Database.
With the goal of tracing gaseous and liquid transport fuels according to the recast Renewable Energy Directive (RED II) and the corresponding Implementation Act for Voluntary Schemes, the co-signatories have voiced their concerns regarding pending separate tradability of certificates from the underlying commodity and system integrity. Further, the lack of information and due notification to market participants would hinder a sufficient preparation regarding the launch of the Union Database.
Recommendations include:
Resume regular focus groups with gas market participants, system operators, voluntary schemes and GO registries on pending operational design issues of the UDB, to ensure and clarify:
- The interaction between national databases and the UDB
- Separate trading of commodities and their climate values.
- The link between national mass balancing and GO schemes and the UDB.
- The precise obligations of economic operators active in different segments of the gaseous value chain.
Adjust the proposed timeline to set 2023 (at least) as a testing year for all fuels. This timeline should be shared as soon as possible with all stakeholders to ensure adequate preparation and to other policymakers to avoid mismatch within the EU policy framework.
Reassure market participants that the launch of the Union Database will occur only when it has proven fully functional based on the following conditions:
- The UDB and national databases are interconnected and transfer of information between national databases is effective and reliable in real-time.
- Tests by market participants and Voluntary Schemes have shown that the UDB actually works in a stable and secure way.
- Voluntary Schemes have been given appropriate time to train their operators as well as auditors from certification bodies.
- A simple, fully tested solution for non-certified and/or off-grid gas suppliers is implemented, and concerned Economic Operators have been trained to interact with the UDB.