Cristiano Fiameni

By Cristiano Fiameni, Technical Director of the Italian Gas Committee
From the speech ‘Methane emissions: the evolution of legislation’
SMART GRID DAYS 2025, 8 – 9 October 2025.

Methane emissions is a topic we cannot avoid addressing, since EU Regulation 2024/1787 on the reduction of methane emissions in the energy sector has been published. We will therefore see the guidelines along which the activity has developed during 2025 and the prospects we can glimpse in the application phase of this Regulation, which is particularly complex.

The operational challenges of the Methane Emissions Regulation

The Regulation was published in July 2024 and came into force on 4 August of the same year. It is important to emphasise this date, because a series of important deadlines originated from that moment.

This measure is particularity invasive. Indeed, it not only sets the objectives but  also maps out the path, leaving little room for the technical sector and causing difficulties from an operational point of view, as it has strong limitations on the modalities that inevitably clash with the practical needs of operators.

As already mentioned, the main objective of the introduction of the Regulation is to reduce emissions; to this end, they must be researched, found, quantified, verified and repaired. This applies to the entire gas chain: transport, distribution, storage and regasification.

On the one hand, covering the entire supply chain is positive. But on the other hand, as the latter is very diverse, the tools to be used should be adapted to each portion of the supply chain. In reality, however, the regulation is one-size-fits-all, and provides a single way of operating regardless of whether one has to work on a regasification plant or on an urban network spread over a city of millions of inhabitants. The requirements and methods of intervention are therefore the same, and this is the crux of the matter from which the critical issues in the application of Regulation 2024/1787 arise.

The fulfilments of the Regulation

Since the entry into force of the Methane Emissions measure, there are several obligations: some are the responsibility of the Member States, while others are the responsibility of the operators or the Commission.

With regard to Member States, several European countries have not yet completed the process of appointing the competent authority. Italy, on the other hand, has already submitted a draft law and made available official e-mails from the MASE (Ministry of the Environment and Energy Security) to which operators can refer for communications.

As mentioned, the operators involved also have certain obligations: in August 2025, for example, they had to submit the first leakage research report (LDAR) on the previous year, and they also had to quantify emissions, using generic emission factors. This meant that even more precise assessments could be made, but the minimum required was the use of literature values of emission factors applied to one’s assets.

The Ministry reported that most operators were able to fulfil this obligation. There will be problems in the coming months, however, because from February 2026 operators will have to submit another report using emission factors specific to their asset. This requires operators to perform an important activity of evaluating their assets, and how to relate this data to factors that have a realistic place in their system. This is not easy so there will be difficulties.

In 2027, however, operators will have to submit a report quantifying emissions from one’s assets and verifying the measures taken on the ground against the results in the atmosphere, i.e., reconciliation. This is a rather ambitious challenge for the sector, given that the Regulation presented the requirements without all the necessary tools being available yet.

The supporting technical standards

Another issue to be taken into account is the instruments, i.e. the technical standards supporting the measure. Indeed, the Regulation not only stipulates that there must be technical standards to support this activity, but also provides that these standards can be recognised by the European Commission as implementing instruments. The body that draws up the standards is the CEN (European Committee for Standardisation), in which several European countries, including Italy, participate.

However, there are critical aspects to this path. The first aspect is that a specific request from the Commission (standardisation request) is needed to draw up standards. This request was submitted in 2024 and it took some time to reach a conclusion. The latest news tells us that the technical phase of discussions between the Commission and CEN has been concluded, and that the contract will be signed shortly. Since the contract provides three years to draft the standards, we could have them by the end of 2028. Therefore, we are faced with an asymmetry: the stricter requirements apply from 2027 onwards, while the standards will perhaps come into force at the beginning of 2028. This represents the first problem.

The second problem is that the Regulation has taken on the honours and burdens of precisely determining technical requirements as well, and this has become an obstacle. Indeed, the Regulation requires the Commission to publish a delegated act specifying the MDLs (Minimum Detection Limits) for technologies and providing guidance on the limits for pre-localisation. The point is that these values have not yet been defined.

An initial stakeholder consultation document came out in 2025, which was supposed to be the basis for producing a subsequent one. The deadline was 5 August 2025, but it was not met. Therefore, we are faced with a doublecritical issue: the first is related to technical standards that are not available due to delays in the Commission’s issuing of the required documents; the second concerns the practical aspect related to operators. The latter, indeed, have obligations that they cannot postpone, and in order to fulfil these obligations they must carry out activities in the field that require investments in technology and equipment.

It must therefore be considered that there are also investments made ‘in the dark’, hoping that industrial best practices will be considered in this delegated act and that consequently these investments will be recognised as valid. Unfortunately, it is a time of great uncertainty.

The work carried out so far and the next steps expected

What have we done in the meantime? The CIG, through the experts made available by its members, participated in the activities and contributed by bringing the Italian position to the European tables.

At European level, it is worth noting the contribution of Marcogaz, the international non-profit association representing the European gas industry, which has produced guidelines for the application of the Regulation. These guidelines provide guidance on the main aspects and introduce two useful elements for operators. Firstly, they provide illustrative diagrams of the process to be followed in accordance with the Regulation. In addition, they include a chapter on the cost-benefit analysis of the activity carried out: the repair of the leak must not cause more environmental damage than the leak itself.

This initial document provides some general guidelines that allow us to assume that this concept will be included in the standardisation request that the Commission will submit to CEN. If this is the case, CEN will be able to develop a chapter dedicated to guidance for operators on cases where the effort is not worthwhile. Especially for those working in the distribution sector, having such indications is very important because the numbers involved are really significant.

Marcogaz in 2024 published guidelines on the Venting & Flaring part and commented in detail on the first consultation paper on the limits proposed by the Commission, which were considered unrealistic for some applications. Indeed, there are both established and modern technologies, but it must be ensured that there is no one way to operate: a neutral approach must be taken in order to achieve the desired result.

In view of the Commission’s request, the CEN decided not to publish the draft on MRV (Monitoring, Reporting, Verification), which started in 2022, but to use it as a technical basis for developing the ongoing standards. The European Technical Committee CEN/TC 234 is developing, in parallel, three standards to support the implementation of the Regulation:

• The first is on the quantification of leaks and associated reporting – MRV (Art. 12).
• The second is on LDAR (Leak Detection and Repair) (Art. 14).
• The third is on Venting & Flaring (Art. 15, Art. 16).

Thus, CEN has already prepared drafts which, in order to be developed and sent to public enquiry, require the two documents we mentioned in the previous paragraphs: the standardisation request and the delegated act.

Lastly, the CIG worked on the drafting of a national guideline that, in compliance with legal requirements, would lead to the practical application of the Regulation for the distribution sector, trying to ‘hold together’ the obligations of the provision with the prescriptions of ARERA (Italian Regulatory Authority for Energy, Networks and Environment).

The activity was completed in November 2025 and was preliminarily presented to the MASE.

The Italian Gas Committee, established in 1953, aims to improve safety and efficiency in the use of combustible gases. In 1960, it joined the UNI, the Italian national standardisation body, thus becoming the official Italian body for standardisation in the fuel gas sector.

As an association comprising institutional and non-institutional members, the IGC covers with its members the entire supply chain, from gas import to transport, distribution, storage, utilisation, equipment, devices and installations.

By Cristiano Fiameni, Technical Director Italian Gas Committee
From the presentation ‘Methane emissions: regulatory updates’
SMART GRID DAYS 2024, 18 – 19 September 2024.

What are the new regulations regarding Methane Emissions that have been finalised and are becoming operational?
In the spring of 2024, Regulation 2024/1787 on the reduction of methane emissions in the energy sector was approved first by the Parliament, then by the Council, and finally published in the Official Journal on 15 July 2024, entering into force on 4 August 2024.

This Regulation has a huge impact: it is directly applicable and does not require national transposition.

The whole gas supply chain is covered, because the Regulation deals with very different industry sectors (just think, for example, of the storage or regasification system and how completely different it is from a city distribution system) and this leads us to foresee some elements of difficulty from the application point of view, because it is difficult to have a single rule that works for all situations.

Let us look in detail at some highlights to better understand the state of affairs.

Enforcement of the Regulation on Methane Emissions

Regulation 2024/1787 lays down standards for accurately measuring, quantifying, monitoring, reporting and verifying methane emissions in the EU energy sector, as well as for reducing them.

The reduction can be achieved through investigations to detect and repair leaks, repair obligations and restrictions on venting and flaring. The Regulation also establishes standards on tools that ensure transparency with regard to methane emissions.

The Regulation apply:

• the exploration and production of oil and gas, as well as the collection and processing of gas;
• the transport and distribution of natural gas, except for measurement systems at the points of final consumption and the parts of the service lines between the distribution network and the measurement system located on the property of the final customers, as well as to underground storage and operations in LNG terminals and plants.

This applies to the entire supply chain concerning the distribution sector, therefore to the pipelines on public land, while measurement stations at the final customer are excluded.

With regard to utility connections, there are critical issues from an application point of view, because the Regulation apply to connections, butfrom the property boundary to the meter are excluded, whereas on public land they are included.

Applications: Article 15

With regard to Article 15 – Restrictions on Venting and Flaring, the Regulation remains structured as before: there is a substantial ban except for emergency or safety reasons.

This approach may be correct in an industrial environment, but in a city network the situation becomes more complicated. So, in this case, it will be necessary to pay the utmost attention to safety and, in some routine activities, it will be necessary to do a flaring instead of a venting.

The competent authorities: appointments and critical issues

One or more competent authorities must be appointed by the Member State six months after the entry into force of the Regulation (i.e. by 5 February 2025). The competent authority will have to monitor and ensure compliance with the Regulation. In some cases, it may also intervene in inspection programmes and may impose sanctions with respect to compliance or non-compliance with the requirements of the Regulation.

On the other hand, operators must submit the report containing the first quantification of emissions to the competent authorities within one year.

The situation becomes more complicated because Article 12 of the Regulation talks about how this quantification activity should be carried out with respect to the technical standards currently being developed and to the provisions of Article 32, stating that ‘Until the date of application of these technical standards or regulations, operators and companies shall follow the most advanced industrial practices and use the best available technologies for measuring and quantifying methane emissions’. It goes on to state that ‘operators and companies established in the Union may use for these purposes the latest OGMP 2.0 technical guidance documents approved by 4 August 2024’.

Harmonised standards: drafting and approval

In Article 32 of the Regulation, the Commission asks CEN (European Standardisation Organisation) to work towards harmonised standards for:

• the measurement and quantification of methane emissions referred to in Article 12(5);
• the Leak Detection and Repair investigations referred to in Article 14(1);
• the necessary equipment, as referred to in Article 15(3) and (5);
• the quantification of methane emissions referred to in Article 18(3);

Once CEN has completed its task, the Commission assesses whether or not the draft standard it has received complies with its request and, if so, the standards are published in the Official Journal. However, the Commission may still adopt delegated acts to establish further standards or parts thereof. The deadline for drafting these standards is spring 2027.

Leaks detection and repair: critical issues (and positive aspects)

By 5 May 2025 for existing sites (and within 6 months from the date of entry into operation for new sites) operators must submit a leak detection and repair programme (LDAR programme) to the competent authorities.

The timeframe is therefore a bit tight, because the authority must be appointed by February 2025, then in May operators must present the programme and by August they must have carried out the first inspection.

How does detection work? After carrying out a leaks search (reference is made to Annex I and II of the Regulation), operators shall repair or replace all components in which there is an emission at or above the specified levels. To understand better: in the worst cases we can be at levels that are 500 or 1000 ppm, which is a very low value.

Once leaks have been detected, repairs should be made immediately if possible. This requirement applies more easily to an industrial site than, for example, the gas network of a large city. The Regulation further state that ‘If it cannot be carried out immediately after detection, the repair shall be attempted again as soon as possible and in any case within 5 days of detection and shall be completed within 30 days of detection‘.

Any delay in the repair must be justified with a report, resulting in a major administrative burden, even disproportionate to the operational intervention required.

The Regulation does, however, leave a small window of opportunity if it can be shown that the leaks are small and difficult to repair, so that continued monitoring and repair could cause environmental damage that outweighs the benefit of repair.

Marcogaz pre-normative activity

Marcogaz, the international non-profit association that represents the European gas industry, has drawn up pre-normative documents on the best techniques to be implemented to carry out specific activities. The relative documents are available on the website https://www.marcogaz.org and can be downloaded free of charge: it’s a series of 9 BATs (Best Available Techniques) regarding ‘Venting and Flaring’.

In 2024, BAT 0 was published, ‘Introductory document to the Best Available Techniques to Reduce Methane Emissions from Venting and Flaring Activities in the Mid-downstream Gas Sector‘.

The other BATs will be:

• BAT 1 – Reduce pressure before venting
• BAT 2 – Mobile recompression
• BAT 3 – Stationary recompression
• BAT 4 – Flaring as replacement of venting
• BAT 5 – High bleed continuous pneumatics mitigation
• BAT 6 – Electrical or pneumatic air starters
• BAT 7 – Use of nitrogen to purge LNG pipes
• BAT 8 – LNG truck loading – dry coupling connectors
• BAT 9 – Excess flow valves in new service lines

In addition, a ‘Guidance for enhancing methane emission reduction and the application of the EU regulation on methane emission’ is being prepared.

At the regulatory level, an activity that started a few years ago on the emission quantification project is coming to an end, with three focuses:

1. Gas infrastructure (the quantification and reporting part), regulated in Article 12 of the Regulation.
2. Leak Detection and Repair, that is, how to carry out investigations and repair programmes, Article 14.
3. Gas Infrastructure, that is, everything related to Venting and Flaring, Article 15.

As we have seen, the technical part supporting the operational articles of the Regulation is the subject of draft standards currently being developed at CEN level. The timeframe is not immediate, as these topics present two difficulties: an objective-technical one, because not everything is already available and consolidated, and an operational one, because at European level countries have different sensitivities.

Agreeing on the content of standards when there are varying national operational practices or regulations makes it even more difficult to conclude the task.

It should be noted, however, that there are many Italian experts who participate in these activities and try to make their own contribution.

The Italian Gas Committee, established in 1953, aims to improve safety and efficiency in the use of combustible gases. In 1960, it joined UNI, the Italian national standardisation body, thus becoming the official Italian body for standardisation in the fuel gas sector.

As an association comprising institutional and non-institutional members, the IGC covers with its members the entire supply chain, from gas import to transport, distribution, storage, utilisation, equipment, devices and installations.