07 Emissions

Our stakeholders consider emissions to be a material topic for Gasunie. Gasunie is also bound by the Paris aligned benchmarks. Under the Greenhouse Gas Protocol (GHG Protocol) we cause CO₂ emissions in all scopes:

• Scope 1 These are all emissions that are a direct result of our own activities. The transmission of natural gas requires energy, energy we use to keep the gas grid at pressure, to blend natural gas with nitrogen, and to compensate for frictional losses during transmission. Gasunie uses natural gas for this (among other things). Combustion of this natural gas produces CO₂ emissions. Furthermore, methane (natural gas) is emitted to the air during management and maintenance work on our infrastructure. Methane (CH₄) is a potent greenhouse gas. 
• Scope 2 These are the indirect emissions from the energy we procure. We procure electricity for our electric compressors and for the production of the nitrogen we use to convert high-calorific gas from outside the Netherlands and from the North Sea fields into Groningen quality low-calorific gas (‘pseudo G-gas’). Scope 2 also includes the electricity consumed in our offices and our installation buildings. 
• Scope 3 These are all indirect greenhouse gas emissions related to upstream and downstream activities in our value chain. Emissions also occur through the provision of services and production of goods we procure, such as steel pipes. The energy we use to maintain the pressure in our networks (obtained from the electricity and gas we use in Scope 1) must be extracted at the beginning of the value chain, and this, too, generates emissions.

We disclose both our location-based and market-based emissions. Disclosing both provides an accurate picture of our emissions and the effectiveness of our investments in decarbonising our energy usage.

We determined the impact and risk listed above based on consultations with internal and external experts. We looked both at our own impact on the climate and at the impact of the climate on our business operations in the value chain. In this Emissions section we describe our own impact on the climate. The impact of the climate on our business operations is discussed in the section Security of Supply.

We have not yet specifically analysed, in detail, the resilience of our strategy and our business model to the impact of climate change. We will, however, carry out this analysis in the future so as to gain a complete picture of the risks.

We want to help society make the transition to a sustainable energy system while also setting a good example ourselves. Reducing our own carbon footprint is one of the ways in which we can keep our social licence to operate. Protecting the environment is part of the role model function our shareholder expects from us.

Climate Transition Plan

Though Gasunie does not yet have a fully developed Climate Transition Plan, we have included an emission reduction ambition in our strategy: by 2045, Gasunie aims to have reached net-zero emissions across all three scopes. By net zero we mean that by 2045 we aim to have cut our carbon emissions by 90% compared to 2020 and are compensating for the remaining 10% by means of carbon removals.

If we take the measures required to turn this net-zero ambition into a net-zero target for 2045, we will no longer be contributing to global warming even before the year required under the Paris Agreement. We believe this ambition is realistic and can be achieved through various emission reduction measures to be taken, this combined with a reduction in the use of our gas transmission networks due to a decreasing gas demand.

There are two reasons why Gasunie has a net-zero ambition but no net-zero target at this stage. The first is that we are awaiting the publication of a framework that applies to the entire sector. This framework, the Oil and Gas Standard (sector-specific emission reduction pathway guidance for the oil and gas sector) of the Science Based Targets initiative (SBTi), is expected in 2025.

For the period 2025-2030, we have a clear picture of how much emissions we want to and can cut, and what this will cost. However, we do not yet have such a clear picture for the period 2030-2045. The speed at which we can reduce our emissions over that period depends on many aspects. For example, we are required by law to guarantee the security of transmission of natural gas in the Netherlands and in the part of Germany in which we operate. Another aspect is that the pace of the energy transition is difficult to predict.

Gasunie aims to have its Climate Transition Plan completed in the medium term, during which time we also want to elaborate what our emission reduction efforts will be up to 2045. We will then review and update the Climate Transition Plan annually to take into account the arrival of new business units, participating interests and emission reduction technologies.

Emission reduction plan

Emission reduction plans form the basis for Gasunie’s future Climate Transition Plan. 
We are developing emission reduction plans for all three scopes. Those packages that will deliver the greatest emission reduction at the lowest cost will be carried out first. We developed our first emission reduction plan in 2024, which has since been approved by the Executive Board. In this emission reduction plan, we aim to cut Scope 1 and 2 emissions by 248.5 kt CO₂e (-40%) by 2030 compared to the base year 2020* and be contributing to the reduction target set. The initial results of this first emission reduction plan are expected in 2025. A summary of the plan is shown in the table below.

To stay on track, we will need to make permanent cuts in carbon emissions between now and 2030. There are several ways to achieve this in and through our business operations. We can, for example, use energy more efficiently, use renewable energy sources, and detect and resolve leaks. And, in some cases, we can even decommission assets without compromising the security of supply and affordability of energy. In our value chain, this concerns finding other means of production, making and using zero-emission construction equipment, and taking a more sustainable approach to materials and components. We are working together with our value chain partners to achieve this.

As mentioned earlier, there are as yet no sector-specific SBTi standards that apply to Gasunie. There are, however, general standards the company can follow. In these general standards, SBTi states that organisations that want to contribute to limiting global warming to the 1.5°C target under the Paris Agreement must reduce their GHG emissions linearly by an average of at least 4.2% per year relative to their base year. We have set 2020 as our base year in our emission reduction plan. This would mean that by 2030 Gasunie would have to have cut the equivalent of 42% of the emissions it produced in 2020. Gasunie has a Scope 1+2 emission reduction target of 34% for 2030, assuming the same transmission volumes (1,034 TWh). We currently expect our transmission volumes to fall to 705 TWh in 2030, which means that a reduction target of 42% by 2030 would appear feasible.

We have not yet conducted an in-depth analysis of potential obstacles that stand in the way of achieving our net-zero ambition. It is, however, important that we map out these potential obstacles so that we can proactively take measures in anticipation of the challenges and risks; accordingly, we will enrich our emission reduction plan with such an analysis.

Scope 1 decarbonisation levers

Scope 1 emissions are all emissions that are a direct result of our own activities. Gasunie’s main focus so far has been to drive back these kinds of emissions. Methane emissions account for a large part of the emissions in this category. These made up 31% of Gasunie’s Scope 1 emissions in 2024 (2023: 34%). Methane has a global warming potential of 28. This means that an equivalent amount of methane is 28 times more harmful than CO₂ in terms of global warming.

The other 69% of Scope 1 emissions consist of emissions from compressor drive systems, heating buildings and heating up gas at gas receiving stations. The new EU Methane Regulation that took effect in 2024 requires us to further reduce our methane emissions. For Scope 1 we are using the following decarbonisation levers:

Energy efficiency (LT)

• Limiting energy needs: At 900 gas receiving stations we are gradually reducing the pressure of gas at inlet points, reducing the temperature of the gas at outlet points, and using a variable boiler water temperature based on the then current heat demand. This has reduced total gas consumption at our Dutch gas receiving stations. We are also considering replacing the current central heating boilers at gas receiving stations with a hybrid heat pump system. We would only need to switch over to the system’s gas-fired boilers when gas throughput is high, like in winter for example. In the near future it will become clear whether this concept can be used at gas receiving stations, because we are dependent on larger electricity connections, for example.
  
  
• Energy-efficient components (ST): Procuring goods with greater fuel efficiency, such as machine components with less frictional resistance.

Preventing emissions (LT)

• LDAR programme: Through our leak detection and repair (LDAR) programme, we detect leaks in connections and appendages (valves, flanges, etc.) at compressor stations, gas receiving stations, metering and regulating stations and valve locations. For this we apply the NEN-EN 15446 standard, which is based on the measuring methodology developed by the US Environmental Protection Agency (EPA). The LDAR programme will continue in full force in the coming years. After all, leaks can occur any time and by maintaining this programme we limit our methane emissions.
  
  
• BERK task force: Over the period from early 2023 to mid-2025, we will be scaling up our LDAR programme by deploying a temporary task force. The BERK task force (‘BERK’ is the Dutch acronym for controlled emission reduction pathway) aims to substantially drive back the number of methane leaks. The basic aim is not to emit any methane, unless there is no other way due to technical or safety reasons. The BERK task force will also get Gasunie ready for the European Commission’s Methane Regulation that came into force in early August 2024. This new EU legislation sets requirements for the frequency of leak detection and how quickly leaks are to be repaired.

Technological emission reduction (MT)

• Mobile recompression: GTS uses a mobile recompression unit to recompress as much of the gas as possible that would otherwise have had to be vented. This gas is then transferred to another pipeline. In 2024, around 1.9 million cubic metres of gas were returned to the network through recompression (2023: 0.8 million m³). With this we avoided emissions of 32 kt CO₂e in 2024. 
  
  
• Nitrogen displacement: One way to avoid having to vent natural gas from a pipeline is to use nitrogen to displace the gas and by this means transfer it to a different section of the pipeline. Though we have not yet used this technology, we will soon do so for the first time when repurposing gas pipelines for our new hydrogen network. We have now included the technology in the specific policy document on methane emissions.
  
  
• Flaring: If recompression is not an option, flaring offers a way to reduce the environmental impact of the methane in the natural gas by burning it off. In 2024, 1,129,832 m³ of natural gas was flared (2023: 342,791 m³). In 2024, flaring instead of venting yielded environmental savings of 16.4 kilotonnes of CO₂e.
  
  
• Mini-recompression units: The pressure down to which recompression units can reduce is relatively high. GUD uses mini recompression units to reduce pressure so that there will be less natural gas left over that we have to flare or vent, which means cutting our methane and other emissions.
  
  
• Zero-emission regulating equipment: In the GTS network, we no longer use gas-emitting regulators in newly built or refurbished installations. We will be replacing pneumatically driven components such as pressure regulators and flow regulators. By the end of 2029 we will have replaced all regulating equipment with emissions with zero-emission variants.

Decommissioning assets (MT)

• Electric-drive compression: In all the operational choices we have to make, emission reduction is a compulsory selection criterion. Where technically and financially possible, we favour electric compression over gas-powered compression. At GUD, at the Rysum site we will replace two gas-powered compressors with electric units. A new electric compressor station is set to be commissioned at the Achim West site in 2026. This will significantly reduce GUD’s gas consumption.
  
  
• Permanent or temporary decommissioning of compressor stations (MT): Due to a decrease in gas consumption and/or lower exports to surrounding countries, certain stations in the GTS and GUD network are no longer needed for gas transmission. These stations are being decommissioned, either temporarily or permanently. GTS has launched its ‘Decommissioning of large installations’ (DLI) programme for the dismantling of a number of stations. With this programme, we want to prevent passing on the costs of installations we no longer use to our customers. The buildings and installations will be removed, but we will keep hold of the property. This land will be put to use in another way, like for a valve location for example. In the future, this property may serve as a location for the compression of biomethane or hydrogen. In line with our aims and targets in the area of circularity and reuse of our assets, we are looking into possible reuse of the released materials and components. The timeline for the DLI programme is as follows:

We may also permanently or temporarily decommission other installations, depending on how quickly the market demand for natural gas decreases.

Scope 2 decarbonisation levers

Scope 2 emissions are indirect emissions from the energy Gasunie procures. We procure electricity for our electric compressors and for the production of the nitrogen we use to convert high-calorific gas from outside the Netherlands and from the North Sea fields into Groningen quality low-calorific gas (‘pseudo G-gas’). Scope 2 also includes the electricity used in our offices and the buildings housing our installations. Besides electricity we also procure heat, mainly for the regasification of LNG. The Scope 2 measures will remain important to us until we cut our emissions to virtually zero or until further reduction is no longer possible; in this we will continue to focus on feasible and affordable reduction measures.

Making energy sources more sustainable

• Decarbonising our electricity consumption (ST): Our electricity consumption in 2024 was completely decarbonised. In 2024, we purchased GOs from European wind farms for our Dutch activities. In Germany, all of our power needs were covered by electricity from sustainable sources in 2024. As a result of these actions, our Scope 2 footprint mainly consists of emissions from procured heat for our gas receiving stations. for which there are no decarbonisation options. 
  
  
• Power Purchase Agreements (PPAs) (MT): Under a five-year contract we signed with Greenchoice, which came into effect in 2024, a quarter of all the electricity we consume (250 GWh) is coming directly from Dutch wind farms. The CFE (carbon-free energy) score we achieved with this was 27%, meaning we exceeded our 25% target. The CFE score measures the degree to which each hour of electricity consumption by Gasunie is matched with procurement of renewable energy from local sources.  A higher CFE score indicates higher use of sustainably generated energy at the time it is generated. One of the ways that this can be achieved is by matching electricity consumption to the generation of renewable energy. Over the coming years we intend to enter into more such PPAs. Procuring green energy directly at the source creates a direct link between generation and our consumption, which is another step up on decarbonising electricity procurement through GOs in terms of quality.

Scope 3 decarbonisation levers

Scope 3 is the third and broadest reporting category of the Greenhouse Gas Protocol. This scope includes emissions across Gasunie’s value chain, i.e. all indirect greenhouse gas emissions related to upstream and downstream activities in our value chain associated with our own business operations.

Gasunie has thus far disclosed only a small part of its Scope 3 emissions in its public report: emissions from business travel and commuting* and from the production of the nitrogen we purchase. In 2024, we identified, for the first time, all of our Scope 3 emissions across all categories as per the GHG Protocol, using 2023 as the base year from which we start calculating reductions. In doing so, we aimed to collect as much high-quality, primary activity data and emission factor data from suppliers as possible.

Gasunie’s main Scope 3 emissions comprise:

• emissions from procured goods and services, comprising mainly pipeline maintenance activities to guarantee the safety and reliability of our network. Emissions from the production of the nitrogen we procure also constitute a significant part of this category; 
• emissions from procured capital goods, which mainly comprise infrastructure development activities (procurement of steel pipes and construction services), and then especially projects with hydrogen and CO₂ pipelines; and 
• upstream emissions from energy consumed: Gasunie uses a great deal of energy to maintain the pressure in the high-pressure network and this energy needs to be extracted at the start of the value chain, and this, too, creates emissions.

Energy efficiency

• Heat pumps (LT): Installing heat pumps at gas receiving stations avoids emissions that arise during natural gas extraction.
• Decarbonising IT (MT): Decarbonising power consumed by the IT systems running the trading platforms in which Gasunie holds a stake.
• Participating interests (MT): Reducing the pipeline emissions of GUD’s participating interests and Gate terminal where Gasunie does not have operational control.

Preventing emissions

• Procurement policy (MT): In 2024, Gasunie adopted a procurement policy under which our invitations to tender will from now on include criteria relating to GHG emissions. Only suppliers who can demonstrate that they are taking ambitious climate measures and setting decarbonisation targets will be awarded new contracts. 
• Internal carbon pricing (LT): In 2024, we launched a long-term tender process for the supply of steel pipelines, using internal carbon pricing (ICP) as one of the award criteria in mini-tenders for the first time.
• Investment policy (LT): We have started developing a sustainable investment policy to prevent an increase in emissions from future energy transition projects. 
• Travel (ST): In 2024, we conducted a survey into the behaviour and preferences of Gasunie employees in the area of commuting and business travel. In 2025, we want to provide public transport passes to all Gasunie employees in the Netherlands to encourage them to choose public transport more often for their commuting and business travel.

Technological emission reduction

• Electric arc furnace (MT): We are switching to pipelines made of scrap steel produced in electric arc furnaces. The first pilot batch of this circular steel from Mannesmann Line Pipe has now been delivered. Using recycled metal cuts emissions by as much as 80%. The first pilot will let us test feasibility and scale-up options, get a good understanding of the price difference between various supply options, and obtain verifiable data on the degree of circularity of this material. We are also negotiating with other suppliers for similar pilots.
• Hydrogen-based DRI technology (LT): Once this technology becomes commercially feasible, we want to switch to steel made from DRI (direct reduced iron) that has been produced using hydrogen rather than natural gas. With hydrogen-based DRI technology, iron can be extracted from iron ore with substantially lower carbon emissions.

Making energy sources more sustainable

• Construction sites (MT): Creating zero-emission building sites by using zero-carbon or low-carbon construction equipment. Our new procurement strategy for engineering and works specifically seeks to partner with contractors and engineering firms in sustainability endeavours. Together with our partners, we want to adopt clean methods in building infrastructure for renewable energy.
• Nitrogen (LT): GTS uses nitrogen to convert high-calorific gas into low-calorific gas (called pseudo Groningen gas, or ‘pseudo G-gas’ for short), which is suitable for use by small-scale gas consumers in the Netherlands. Where possible, we get our nitrogen suppliers to decarbonise the energy they use to produce nitrogen by purchasing Guarantees of Origin (GOs).

Decommissioning assets

• Compression (MT): Replacing gas-powered compressors with electric compressors at Gasunie Deutschland (GUD). This avoids emissions from natural gas extraction.

We put a lot of time into improving the completeness, accuracy, timeliness, and traceability of our reported emission volumes. In 2024, we launched our Emissies in Kaart (Emissions mapped out) programme. Through this programme, emission registration, reporting, and management software are linked to our procurement software systems to get a constant and comprehensive view of our emissions across all scopes, allowing us to add further rigour to our annual plans wherever we can.

As stated previously, Gasunie intends to invest a total of € 12 billion as part of its Strategy 2030. Of this amount, one third is slated for maintenance and renewal of our natural gas infrastructure, which also includes our decarbonisation investments.

Our emission reduction plans are part of EU Taxonomy activity 4.14 Transmission and distribution networks for renewable and low-carbon gases. In 2024, € 42.2 million CAPEX and € 6.3 million OPEX were included under activity 4.14 relating to emission reduction plans.

Where possible, when formulating targets we do this based on criteria that are similar to those of the Science Based Targets initiative (SBTi). As soon as SBTi’s Oil and Gas Standard (sector-specific emission reduction pathway guidance for the oil and gas sector) becomes available, we will study it and assess how it fits within Gasunie’s business model and strategy.

Our 2030 target for methane emissions, our 2030 target for Scope 1 and market-based Scope 2 emissions, and our Scope 3 targets for 2030 and 2035 have all been validated by means of a second party opinion provided by an external party (other than the assurance provider) in the context of the Sustainability-Linked Bond framework (2025 edition).

Methane emissions

Our methane emissions (CH₄) have to be below 70 kilotonnes (kt) of CO₂e by 2030, which boils down to a 49% reduction compared to the base year of 2020. Of this 70 kilotonnes target, Gasunie’s Dutch assets have to deliver 50 kt and Gasunie’s German assets 20 kt. This target is not subject to how our transmission volumes develop. Our methane emissions make up a significant part of our Scope 1 emissions.

Scope 1 and market-based Scope 2 emissions

In a year when we transport large volumes of natural gas, we produce more emissions than in a year when we transport less natural gas. With this simple fact in mind, we have set a relative goal for the combination of our Scope 1 and market-based Scope 2 emissions, based on GTS’ and GUD’s combined transmission volumes equalling those of the base year of 2020 (1,085 TWh).

The formula for this is as follows:

CO₂e [kilotonnes] = 70 [kilotonnes CO₂e] + (0.137 × transmission volume [TWh])

In 2020, we emitted a total of 330 kilotonnes of CO₂e across Scopes 1 and 2 (market-based). By 2030, this figures must not exceed 219 kilotonnes, provided that volumes remain unchanged, which means a 34% drop.

Scope 3 emissions

The biggest part of Gasunie’s Scope 3 emissions is caused by the development of new infrastructure to enable the energy transition. Given that we will be running more and more energy transition projects, we will also procure more and more goods and services, causing our Scope 3 emissions to rise. With this in mind, Gasunie has adopted a carbon intensity reduction target that covers 77% of all our Scope 3 emissions.

The following categories come under Gasunie’s Scope 3 target: emissions from the production and transport of the steel, nitrogen, fuels, and electricity we purchase, and emissions from procured construction services and investments. Gasunie is striving to reduce its Scope 3 emissions by 51.6% in kilogrammes of CO₂e per euro of procurement spending by 2030 and for a 66.3% reduction by 2035 compared to the base year of 2023.

This target is an economic intensity target in terms of kilogrammes of CO₂e per euro spent, creating room for spending to grow while minimising the impact on the climate. We have calculated our Scope 3 targets using SBTi’s prescribed calculation tool for the validation of climate targets. We tested the feasibility of these targets by identifying the reduction measures and their maximum reduction potential based on external market developments and possible industrial decarbonisation options. In carrying out this exercise, we made assumptions that we need to assess together with our suppliers and partners.

Our Scope 3 ambition level contributes to limiting global warming to well below 2°C.* The time frame proposed for this target is 2023-2030, with an additional target for 2035 for a future net-zero target.

We have developed our reduction targets based on SBTi standards and guidance. SBTi requires companies to include at least two thirds of their total Scope 3 emissions in their greenhouse gas reduction targets for the short term. Gasunie has decided to limit the target for Scope 3 emissions in the short term to sources that produced 77% of the Scope 3 emissions in 2023. We cannot yet have SBTi validate the target proposed by Gasunie because Gasunie generates more than 50% of its revenue from the transmission of fossil fuels. This will change as soon as SBTi publishes its Oil and Gas Sector Standard.

Given that Gasunie does not own or sell the gas we transport, the emissions from gas usage are not included in our Scope 3 inventory or target. On this point we deviate from SBTi’s general guidance. That said, we still believe that it is important that we provide an overview of the climate impact caused by the use of the gas by the end users of our customers. We regularly report on this impact to the Dutch authorities. We have set the emissions produced by end users as they burn the natural gas we transported at 179.5 megatonnes of CO₂e for 2024 (2023: 196.7 Mt CO₂e).

In 2020, Gasunie Nederland and Gasunie Deutschland transported 1,085 TWh of natural gas between them. Assuming that these transmission volumes do not change, this means emissions cannot exceed 219 kilotonnes of CO₂e at corporate level in 2030. The share of methane emissions must not exceed 70 kt of CO₂e (regardless of the transmission volumes), with 50 kt of CO₂e emitted in the Netherlands and 20 kt of CO₂e in Germany, compared to 2020.

When this target was set, we assumed that the global warming potential (GWP*) of one kilotonne of methane was 25 times higher than that of a kilotonne of CO₂e. However, methane is a more harmful greenhouse gas than initially thought, and in 2022 the GWP for this gas was upped to 28 based on new scientific insights, but we did not adjust our formula accordingly, meaning that our reduction target became more ambitious.

Our methane emission target

In 2024, we managed to stay on track to meet our methane emission reduction target. In the reporting year, our methane emissions totalled 106.1 kt CO₂e compared to 122.1 kt CO₂e in 2023.

Our Scope 1+2 target

In 2022 we brought EemsEnergyTerminal into operation. Due to the large amount of energy needed to power this LNG terminal, we are no longer on track to hitting our 2030 reduction target for Scopes 1 and 2.

In June 2024, we announced that we, for the sake of security of supply, were considering extending operation of EemsEnergyTerminal beyond 2027. Keeping EemsEnergyTerminal open for longer would mean a permanent increase in our Scope 1 and 2 emissions, putting the emission target for 2030 beyond our reach, unless we can design a substantial emission reduction package for EemsEnergyTerminal for after 2027 as well. We are currently considering how to proceed in this situation and exploring emission reduction options that would be feasible if we were to keep running the LNG terminal after 2027.

The decrease compared to 2023 was mainly caused by the use of the EemsEnergyTerminal. Regasification of LNG requires heat, which in this case is currently being supplied using water from the port and heating this using boilers installed on shore. Until half way through 2023 the heat was still being supplied by generators on board the vessels. In 2024, EemsEnergyTerminal’s energy requirement was 42% lower than in 2023. In total, 35% less LNG passed through EemsEnergyTerminal than in 2023.

We realise that the use of EemsEnergyTerminal may hold us back from achieving our emission reduction targets. We have not yet carried out an assessment of these potentially locked-in GHG emissions.

Location-based

This figure is based on the greenhouse gas emissions caused by the generation of electricity in the region where the electricity is used. The location-based figure is then calculated by multiplying the electricity consumption (in kilowatt-hours, kWh) by the CO₂ emission factor for electricity in accordance with the list of CO₂ emission factors.

Market-based

This figure is calculated based on the greenhouse gas emissions from the energy installations where the procured electricity originates. We use Guarantees of Origin (GOs)* to prove the renewable source of the electricity. In the Netherlands, Gasunie purchased GOs from European wind farms in 2024. In Germany, Gasunie procured green electricity directly from its electricity supplier. In total, we compensated 99.7% of our total Scope 2 emissions in 2024.

We disclose both location-based and market-based emissions to obtain insight into our energy usage and the way we procure energy.

The Appendix to the Sustainability Statement includes the emission tables prescribed in the ESRS, as well as the judgements and estimates we used with regard to our Scope 3 calculation and information on our energy consumption and the energy mix.