This document sets out IAM CARBONZERO, S.L.’s comments on the proposed remuneration methodology for natural gas distribution, which is expected to apply from October 1, 2026.

General comments

First, operators active in natural gas production, distribution, transmission and supply view positively the clarity of presentation that the Commission’s services, and in particular the Hydrocarbons Subdirectorate, have brought to the drafting of the Report and the proposed Resolution.

This effort is supported by the Evaluation Report on the previous remuneration model [1], which, with sufficient advance notice, complements the new model proposal.

Measures relating to energy policy

Regarding the appropriateness of the proposal, and beyond the need for its approval due to the expiry of the previous model in September 2026, it should be noted that the new model lacks, in our view, a sufficiently strategic vision. This limitation stems from the very insufficiency of the energy policy guidelines [2], which do not allow the remuneration model to be properly aligned with an energy transition scenario consistent with energy planning and the country’s “macro” decarbonisation objectives.

In this regard, the guidelines present relevant inconsistencies with respect to the general objectives of decarbonising the Spanish economy. In particular, in Articles Two and Three [3] it is established that:

• The remuneration regime must contemplate a scenario of declining demand for fossil fuels.
• It must be avoided that the remuneration of facilities leads to tariff increases incompatible with an affordable supply.

These premises reflect an unresolved tension. On the one hand, a demand-reduction scenario aligned with decarbonisation is acknowledged. On the other, the intention is to avoid the impact on tariffs that such a scenario could entail, which limits the economic signal needed to accelerate the transition towards a more decarbonised economy.

This inconsistency is reproduced in other areas of the proposal. Thus, it contemplates the possible need for new infrastructure, including that intended to foster the development of renewable gases, reduce greenhouse gas emissions and ensure security of supply—in particular, increasing system resilience—. However, at the same time, limitations are established that may discourage such investments.

Need for quantitative targets

The guidelines should establish, at least, indicative numerical targets. In their current formulation, there is a risk that they attempt to address all stakeholders simultaneously—network operators, renewable gas producers, consumers and users—without defining a clear prioritisation framework. In this sense, the targets should be set in quantifiable terms of:

• Renewable gas penetration.
• Overall emissions reduction.
• Development of new infrastructure needed to integrate these gases.
• Definition of the remuneration methodology applicable to this infrastructure. (these are the only facilities that can be developed “ex novo”, and therefore guidance aimed at reducing the administrative burden is contradictory)
• Determination of an indicative cap on the increase in tariffs resulting from decarbonisation objectives.

It is not consistent for tariff reductions and maintaining supply affordability to act as the sole guiding criterion, without considering their impact on the incentives needed for decarbonisation.

Likewise, in a country with coverage of approximately 22% of gas-supplied municipalities and with a high dispersion of renewable gas production sources, it should be considered that their integration into the system may require new infrastructure. However, the proposal limits the possibility of incentivising facilities that may be underutilised in the medium term (4), which introduces an additional constraint.

Regulatory framework and model coherence

All of the above highlights an insufficiently consistent [5] regulatory framework, in which it is complex to develop a remuneration model proposal fully aligned with energy and climate objectives.

A specific comment is presented below.

On the remuneration concept of an incentive for the injection of other gases that do not require prior blending with natural gas

The inclusion of a specific incentive for the injection of other gases is viewed positively. However, from the perspective of renewable gas plant operators, the proposal presents several unresolved issues that require clarification.

1. Economic justification of the incentive

• It is not clearly defined what consideration distributors receive for the envisaged amount, estimated at €23 million on average over the regulatory period.
• Nor is the economic limitation of the incentive justified in relation to the reduction in remuneration recorded in the previous regulatory period.

2. Regulatory justification

• It is not specified whether this incentive will continue in subsequent regulatory periods.
• Nor is it determined whether it responds to the development of specific assets or to new regulatory provisions.
• Its coordination with other regulatory initiatives, such as those envisaged in the transmission area, is not sufficiently clarified.

3. Technical justification and system design

• It is not defined which facilities distributors must develop to justify such remuneration.
• No equivalent incentive is established for injection into primary and secondary transmission networks.[6]
• The proposal may generate a cross-subsidy effect between activities without adequate justification in terms of investments or associated costs.
• The unit value of the incentive and its calculation are not justified.

Considerations on infrastructure development

Finally, it should be noted that, given the limited gas infrastructure available in Spain for the integration of renewable gases—below the European average—the development of new infrastructure should be a priority objective.

In this context, it is pertinent to consider the need to promote, among others, the following actions:

• Connection facilities.
• Injection modules.
• Direct connection lines.
• Reverse-flow systems.
• Quality adjustment equipment at critical points (international interconnections, underground storage and customers sensitive to gas composition).

Consequently, it is worth considering whether promoting this infrastructure, charged to the system itself, should not be a priority to facilitate the effective integration of renewable gases.