Brussels, 13 June 2023 -- Dear Minister, The signatories of this letter call on the European Union energy ministers to be decisive on a matter that will define EU climate ambition on methane mitigation.

In the coming weeks, the Council of the European Union will engage in negotiations with the European Parliament and European Commission regarding the Regulation on methane emissions from the energy sector. This legislative proposal holds significant potential for driving positive change and enabling the EU to meet its greenhouse gas reduction target of 55% by 2030 and stay within 1.5°C under the Paris Agreement. It also serves as a crucial opportunity for the EU to establish itself as a global leader in implementing the Global Methane Pledge, thereby reinforcing its credibility on the international stage.

But this is only possible if the outcome of the trialogues comes with the extension of the monitoring reporting and verification (MRV), leak detection and repair (LDAR) and limits to venting and flaring (LVF) framework to the whole supply chain, imports included. About three-quarters of total methane emissions in the oil and gas operations occur upstream and nearly all of methane emissions from coal operations, which means that methane emissions associated with fossil fuel imports are mostly emitted before reaching the EU borders. The EU therefore needs to take its responsibility for the outsized role it plays in driving global methane emissions and spur meaningful change in exporting countries.

In its General Approach, the Council of the European Union failed to include any substantive measures to address the critical issue of imports, despite the numerous co-benefits at stake.

• First, in the Impact Assessment for its proposal for an EU Methane Regulation, the European Commission found that 43% of projected methane emissions can be abated at zero cost by 2030, 63% can be abated at less than low cost and 77% can be abated at less than the sum of social benefits. This means reducing methane emissions in the energy sector is extremely cost-effective.
• Second, the International Energy Agency (IEA) has found that if exporters to the EU were to put in place measures to limit flaring, they could increase gas exports by more than 45 billion cubic meters using existing infrastructure. This is equivalent to almost 1/3 of Russian gas exports to the EU in 2021, a particularly significant factor given the ongoing energy crisis and escalating prices.
• Third, the provisions on imports will only be in place in 2026. By then, the EU, in line with REPowerEU, will have weaned off Russian fossil fuel imports, as well as reduced its overall gas consumption. Moreover, jurisdiction such as the United States and Canada will have enacted legislation to mitigate methane emissions in their respective oil and gas sectors, allowing the EU to be in the position to choose where to import from and prioritise exporters with regulations in line with the EU requirements – going from a sellers’ market to a buyers’ market.

Moreover, the EU frequently adopts mandatory requirements on imports accompanied by measures to promote compliance. Examples include illegally harvested timber under the EU Timber Regulation, sustainable biofuels and biomass under the Renewable Energy Directive and HFC-23 by-product destruction under the EU F-Gas Regulation, among others. This is how we ensure sustainable production and consumption.

For these reasons, we urge you to ensure supply-chain coverage in the EU Methane Regulation, especially important against the backdrop of this critical decade of climate action to remain below 1.5°C.

The European Parliament has adopted amendments to the legislative proposal to extend the MRV, LDAR and LVF framework to imports. We hope the Council of the European Union will be equally resolute to act decisively to reduce methane emissions in the energy sector and support their inclusion in the final text.

Thank you in advance for your time and consideration. We remain at your disposal for any questions or additional information.

Yours sincerely,

Mary Rice, Executive Director Environmental Investigation Agency (EIA)

On behalf of Mihai Stoica, Executive Director, 2 Celsius

Conal Campbell, Coal Mine Methane Policy Analyst, Ember

Sascha Müller-Kraenner, Executive Director, Deutsche Umwelthilfe

Esther Bollendorff, Senior EU Gas Policy Coordinator, CAN Europe

Angelos Koutsis , Energy Policy Officer, Bond Beter Leefmilieu

Enrico Donda, Campaigner, Food and Water Action Europe

Flavia Sollazzo, Senior Director EU Energy Transition, Environmental Defense Fund Europe

Suzaane Maas, Climate Campaign Coordinator, Friends of the Earth Malta

Liset Meddens, CEO, Fossielvrij Nederland

Jonathan Banks, Global Director, Methane Pollution Prevention, Clean Air Task Force

Veronika Murzynova, Energy Transformation Expert, Centre for Transport and Energy Collective We smell gas

Renato di Nicola, Campagna Per il Clima Fuori dal Fossile

Angelo Gagliani, Professor, Emergenza Climatica

Simona Ricotti, Energy Campaigner, Rete Ambientalista

Angela Deegan, Not Here not Anywhere

Cosimo Quaranta, NoTAP