Luis Miguel Hurtado Coronado
ARIA
Formentera, 15, Reus. 43205. Spain

27 October 2025

Dear Access to Documents Team,

Pursuant to Regulation (EC) No 1049/2001 and Regulation (EC) No 1367/2006, I request access to the following documents held by DG ENER:

Scope of request

- All communications and records between representatives of DG ENER and (a) the Government of the Republic of Azerbaijan, including the Ministry of Energy, and/or (b) State Oil Company of the Republic of Azerbaijan (SOCAR) or their subsidiaries/representatives, where the EU Methane Regulation was discussed.

- All communications and records between the EU Delegation in Baku and (a) DG Ener, and/or (b) the EEAS, where the EU Methane Regulation was discussed.

Timeframe: 1 November 2024 to 31 October 2025.

Record types included (non-exhaustive)

Emails and attachments (.eml/.msg preferred), letters, notes verbales, meeting requests, agendas, participant lists, briefings, talking points, Q&A, slide decks, non-papers, minutes/readouts, action trackers, teleconference summaries, instant messages used for official business (e.g., MS Teams/WhatsApp/Signal), calendar entries, and any follow-up correspondence.

Counterparties and disambiguation

Azerbaijan entities: “Ministry of Energy of the Republic of Azerbaijan,” “SOCAR,” “State Oil Company of the Republic of Azerbaijan,” “SOCAR Trading,” “SOCAR Europe.”
Topics/keywords (apply Boolean/proximity where supported): “methane regulation” OR “EU Methane Regulation” OR "EUMR" OR “CH4” OR “methane MRV” OR “methane intensity” OR “venting” OR “flaring” OR “leak detection and repair” OR “LDAR” OR “import standard” OR “methane transparency.” Optional context terms: “gas imports,” “Southern Gas Corridor,” “Caspian,” “supply security.”

Likely custodians/locations to search (non-exhaustive)

• DG ENER Cabinet of the Director-General; relevant Directors and Units covering gas markets, international energy relations, and decarbonisation of gases; stakeholder engagement mailboxes.
• Shared drives, ARES/e-DOMEA registries, and meeting calendar systems used for external stakeholder/government engagement.

Timeline, format and delivery

Kindly process within the statutory timeline (15 working days, extendable once with reasons). Rolling, partial releases are welcome. Please provide documents electronically in machine-readable form. Where available, supply native files for spreadsheets/presentations and preserve metadata. Scan any paper-only records at readable resolution.

Transparency, redactions, and third-party consultation

If Article 4 exceptions are invoked, release the remainder with targeted redactions and cite the specific legal basis per excerpt. Given the environmental nature, apply Regulation 1367/2006 and conduct the overriding public-interest test line-by-line. Where third-party consultation is required, proceed under Article 4(4) without delaying partial release.

Administrative handling
Please register this request and provide the case number. If parts are better handled by another service (e.g., SG, TRADE, CLIMA, or EEAS), transfer those parts under Article 6(2) and inform me. If you consider scope optimisation necessary, first provide a document inventory and/or hit counts by custodian and month to enable targeted narrowing.

Sincerely,
Luis Miguel Hurtado Coronado
ARIA

Dear Access to Documents Team,

I kindly request that this message be forwarded to the authority responsible for handling confirmatory applications.

I hereby submit this confirmatory application under Articles 7(4) and 8 of Regulation (EC) No 1049/2001, concerning my access-to-documents request titled “DG ENER communications with Azerbaijan on the EU Methane Regulation.” The application is necessary because no reply has been issued within the statutory deadline, resulting in a constructive (implicit) refusal.

1. Background and scope of the original request

On 27 October 2025, I requested access to all communications and records held by DG ENER and the EU Delegation in Baku relating to exchanges with:

a) the Government of the Republic of Azerbaijan (including the Ministry of Energy), and/or

b) SOCAR and its subsidiaries/representatives,

where the EU Methane Regulation was discussed.

The request covers the period 1 November 2024 – 31 October 2025, and includes emails, letters, briefings, minutes, calendar entries, instant messages used for official business, and other relevant records, as detailed in the submission.

It also specifies custodians, search locations, keywords, and handling instructions, including rolling releases, metadata preservation, third-party consultation, and partial access obligations.

2. Failure to respond within the legal deadline

The institution did not provide a reply within the 15-working-day period established by Article 7(1), nor was I informed of any extension under Article 7(3).
This constitutes a breach of the procedural obligations under Regulation 1049/2001 and an implied refusal under Article 7(4), which triggers my right to request a confirmatory review.

3. Need for a full assessment, including environmental transparency obligations

Because no reasoned initial decision has been communicated, it is impossible to assess:

a) whether a complete and adequate search was conducted across all relevant custodians and registries;

b) whether any exceptions under Article 4 were invoked, and if so, whether these were applied correctly;

c) whether DG ENER considered my explicit request for partial access, per Article 4(6);

d) whether the mandatory overriding public interest test under Regulation (EC) No 1367/2006 was carried out on a line-by-line basis.

Given the environmental nature of the subject matter (methane emissions, MRV, import standards, transparency, flaring/venting), these obligations are particularly stringent.

4. Request for review and next steps

I therefore respectfully request that DG ENER:

a) Conduct a complete confirmatory review of my original request.

b) Perform an exhaustive search across all relevant units, shared drives, mailboxes, and communication platforms.

c) Apply Regulation 1049/2001 and Regulation 1367/2006 correctly, including the obligations on partial access and overriding public interest.

d) Issue a reasoned confirmatory decision and release the documents, or all disclosable parts thereof, in machine-readable electronic form.

I remain available for any clarifications needed to facilitate processing.

Sincerely,
Luis Miguel Hurtado Coronado
c/ Formentera, 15, 43205 - Reus
Tarragona - Spain