Here you will find our public consultations, joint letters, position papers, and key contributions shaping the future of eNG.
GHG Protocol - High Level Recommendations
As part of the Let Green Gas Count initative, e-NG with fellow industry associations engaged in renewable and low-carbon fuels, has published high-level recommendations reagrding the treatment of these solutions in the Greenhouse Gas Protocol and corporate accounting frameworks.
The recommedations follow a joint letter and global call, sent in Februars this year (see futher bellow and here) and the request from July.
These recommendations provide interim guidance to ensure transparent and harmonized recognition of renewable gases such as biomethane and e-NG in GHG accounting. They set out six quality criteria for certificates, clear rules for LCA based reporting, treatment of biogenic CO2 and avoided emissions, and guidance for auditors and corporates.
GHG Protocol - Request for Strategic Action Regarding Market Instrument Guidance and Interim Clarity
On behalf of the Let Green Gas Count Coalition, a follow-up request to the Joint Letter from February (see further below and here https://is.gd/c72hS3) was sent to the Greenhouse Gas Protocol to address the gap in guidance for the use of market-based instruments in Scope 1 reporting. This lack of guidance has now been in place for over five years and continues to significantly harm our industry and the industries that need renewable gas to decarbonise.
Submission to ISCC - Public consultation on the Mass Balance Guidance document (Version 1.0)
Comments on the draft ISCC EU Mass Balance Guidance Document (Version 1.0).
GHG Protocol - A global call to support decarbonisation of corporates and industries
GHG Protocol Should Fully Recognise Robust Market Instruments in End-Users’ Scope 1 Emissions Inventories
Answers to MEP Christian Ehler’s call for input regarding energy omnibus
The eNG Coalition’s answers to MEP Christian Ehler’s call for input regarding energy cost drivers, simplification needs, and the reduction of regulatory and administrative burdens.
1) Cost drivers needing EU action
2) Requirements to simplify, change, or abolish
3) How to dramatically reduce regulatory & administrative burden
Sustainable Transport Investment Plan
Sustainable Transport Investment Plan (STIP). This plan is not only timely but also strategically critical. It provides a unique opportunity to create the right investment framework for the decarbonization of transport across all modes including maritime, aviation, road, and rail, while strengthening Europe’s competitiveness, energy security, and industrial leadership. We strongly support the STIP’s stated objectives of de-risking private investment, scaling renewable and low-carbon fuels, and strengthening Europe’s strategic autonomy.
EU Industrial Maritime Strategy
As decarbonisation and strategic autonomy take centre stage, the maritime sector must embrace a technology-neutral approach that fully integrates renewable and low-carbon fuels such as e methane (e-NG) and e-LNG into its long-term policy vision. This contribution aims to highlight the untapped potential of these fuels for industrial decarbonisation, infrastructure resilience, and maritime competitiveness while offering actionable proposals for recognition and integration into the EU maritime framework.
Submission to ISCC - Public consultation on the Mass Balance Guidance document (Version 1.0)
Comments on the draft ISCC EU Mass Balance Guidance Document (Version 1.0).
State Aid Framework accompanying the Clean Industrial Deal
Responses on behalf of the eNG Coalition to the Public Consultation on the Clean Industrial Deal State Aid Framework (CISAF). Based on the Position Paper on the EU Clean Industrial Deal.
Position Paper on the European Clean Industrial Deal
eNG Coalition welcomes that the European Commission’s Clean Industrial Deal aims to drive forward the decarbonisation of European industry while maintaining global competitiveness. This initiative represents an important step towards a sustainable industrial policy, however it does not fully acknowledge the role of all renewable and low-carbon gases, particularly eNG (electrical natural gas), as viable solutions for industrial decarbonisation and energy security. The eNG Coalition believes that a technology-neutral approach should be adapted to support the industrial transition, infrastructure optimization, and long-term energy security. In this position paper, we highlight the opportunities and gaps in the Clean Industrial Deal and provide concrete recommendations to ensure renewable and low-carbon gases play a central role in Europe’s decarbonization strategy.
Call for action: Urgent need to recognise third country exports of gaseous fuels under the Union Database
eNG Coalition and the co-signatories of this joint statement call for immediate action by the European Commission to ensure the full recognition of imported sustainable biomethane, biomethane-based fuels and other renewable gases and fuels produced in compliance with the Renewable Energy Directive III rules in the Union database (UDB).
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RFNBO informal coalition
Reality Check for European Hydrogen Policy to Adjust the Course
United Kingdom (UK) Public Consultation RTFO
Response to the RTFO Consultation on statutory review and scheme evolution in U.K.
German Public Consultation
Advocating for increased funding support for synthetic methane projects in Germany,
As part of the Let Green Gas Count initative, e-NG with fellow industry associations engaged in renewable and low-carbon fuels, has published high-level recommendations reagrding the treatment of these solutions in the Greenhouse Gas Protocol and corporate accounting frameworks.
The recommedations follow a joint letter and global call, sent in Februars this year (see futher bellow and here) and the request from July.
These recommendations provide interim guidance to ensure transparent and harmonized recognition of renewable gases such as biomethane and e-NG in GHG accounting. They set out six quality criteria for certificates, clear rules for LCA based reporting, treatment of biogenic CO2 and avoided emissions, and guidance for auditors and corporates.
GHG Protocol - High Level Recommendations
On behalf of the Let Green Gas Count Coalition, a follow-up request to the Joint Letter from February (see further below and here https://is.gd/c72hS3) was sent to the Greenhouse Gas Protocol to address the gap in guidance for the use of market-based instruments in Scope 1 reporting. This lack of guidance has now been in place for over five years and continues to significantly harm our industry and the industries that need renewable gas to decarbonise.
GHG Protocol - Request for Strategic Action Regarding Market Instrument Guidance and Interim Clarity
GHG Protocol Should Fully Recognise Robust Market Instruments in End-Users’ Scope 1 Emissions Inventories
GHG Protocol - A global call to support decarbonisation of corporates and industries
Comments on New York Draft State Energy Plan
Comments on the New York State Energy Planning Board’s (EPB) recently published Draft State Energy Plan (SEP).
Request for Comments on “Renewable Fuel Standard (RFS) Program: Standards for 2026 and 2027, Partial Waiver of 2025 Cellulosic Biofuel Volume Requirement, and Other Changes”
At this stage, eNG Coalition’s primary goal is to ensure that e-NG is properly included as a qualifying renewable fuel within the RFS program. Our comments provide essential background information regarding the production process and benefits of e-NG, as well as a justification for its inclusion as an eligible pathway.
Request for Comments on Inquiry Regarding the Future of Natural Gas
Comments in response to the Maine Public Utilities Commission’s (MPUC) Initial Request for Comment pursuant to the recent Inquiry Regarding the Future of Natural Gas (Docket 2025-00145).
Request for Information - Clean Fuels R&D and Pilot to the New York State Energy Research and Development Authority’s (NYSERDA)
Response to the New York State Energy Research and Development Authority’s (NYSERDA). Request for Information (RFI) titled Clean Fuels R&D and Pilot (RFI 5985)
Comments on 45 Clean Fuel Production Credit: Notice 2025-10 and Notice 2025-11
Comments pursuant to the U.S. Department of the Treasury’s (Treasury) Request for Comments in response to Section 45Z Clean Fuel Production Credit; Request for Public Comments and Section 45Z Clean Fuel Production Credit; Emissions Rates; Request for Comments (collectively, Draft Guidance).
USA Request for Information (Department of Energy)
Request for Information on Defining Sustainable Maritime Fuels in the United States