Enagas SA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Enagás provides an unusually detailed picture of its climate-related lobbying. It names numerous individual EU initiatives it has worked on – for example the proposed Regulation on methane-emissions reduction in the energy sector, the FuelEU Maritime Directive, amendments to the REPowerEU recovery plan, several delegated acts under the Renewable Energy Directive (EU 2018/2001), the Sustainable Finance Package (including the Taxonomy Regulation and Green-Bond standard), the LIFE 2014-2020 evaluation, consultations under the Fit-for-55 package, and the Alternative Fuels Infrastructure Directive. The company also explains how it lobbies and who it lobbies. It records making formal submissions to European Commission public consultations, holding “bilateral meetings with the EC, ACER, the Florence School of Regulation, UNEP and UNECE,” sending written “methane policy recommendations … to the EC and other authorities,” and working through associations such as GIE, ENTSOG, Hydrogen Europe and MARCOGAZ. Targets are clearly identified – principally the European Commission, the European Parliament and Council, and specific directorates or agencies mentioned in the consultation links it supplies. Enagás is similarly explicit about the outcomes it pursues. It “fully supports and promotes the development of a Technical Standard that helps natural gas operators to harmonize the identification and calculation methodology of methane emissions,” backs creation of “an EU methane regulatory framework,” advocates extending EU financing rules “to boost new vectors such as hydrogen,” calls for a “cost-effective regulation that maximises the results of the mitigation efforts” on methane, seeks “more flexible temporal correlation that allows hydrogen industry to develop in a critical phase,” and presses for “recognising the technological neutrality of the infrastructure” so that LNG, CNG and renewable gases can continue to be used during the transition. These positions are presented together with the reasons Enagás gives for them, showing clear policy preferences rather than generic aspirations. Taken together, the breadth of specific policies named, the precise description of engagement channels and policymaking targets, and the detailed, measurable objectives the company sets out demonstrate a very high level of transparency in Enagás’s climate-policy lobbying. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate Enagás has established a structured framework to align its lobbying, particularly via trade associations, with its climate strategy and the Paris Agreement. It “ensures that our commitment to decarbonization is also reflected in ... our lobbying activities and/or relationship with trade associations ensuring their alignment with the Paris Agreement” through a three-step system: an “evaluation of the degree of alignment of the purpose of the initiative and/or association with that of Enagás,” a management of partnerships “in line with our stakeholder management model,” and “periodic reporting of information on activities and resources” via the European Transparency Register. This management is led by the Directorate General for Energy Transition. However, while these indirect lobbying controls are well-defined, the company does not disclose a similarly detailed governance process for its direct lobbying engagements nor evidence of a dedicated audit or board-level review specifically for climate-related lobbying, making its oversight of direct advocacy less transparent. 2