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Bellona Europa

Bellona Europa is an independent non-profit addressing climate and environmental challenges through solutions-oriented work with civil society, governments, and industry.

Lobbying Activity

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

19 Jan 2026 · Exchange of views on the Carbon Border Adjustment Mechanism (CBAM)

Response to Land use, land use change and forestry – establishing trajectories towards 2030

12 Dec 2025

Please find attached Bellona Europa's feedback.
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Bellona Europa Urges Scientific Integrity Over Rushed Taxonomy Simplification

5 Dec 2025
Topic — A review updating the standards for the EU list of sustainable investments.
Message — Bellona Europa calls for a full impact assessment and strict reporting requirements. They advocate for digital tools to simplify compliance instead of reducing environmental obligations. The group also demands mandatory carbon emissions reporting for all new buildings.123
Why — Robust rules ensure the taxonomy remains a credible tool for the green transition.4
Impact — Fossil fuel and logging companies would lose access to green capital markets.56
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Bellona Europa calls for industrial-scale circular economy reforms

5 Nov 2025
Topic — EU proposal to remove barriers for waste recycling and secondary materials
Message — The organisation requests EU-wide harmonisation of end-of-waste rules, mandatory circular procurement criteria, and fiscal measures like landfill taxes. They want circularity treated as core industrial policy, not just waste management, with support for reuse and repair alongside recycling.1234
Why — This would create predictable markets for their advocacy priorities and align EU industrial policy with climate goals.56
Impact — Primary material extraction industries lose as subsidies are removed and circular alternatives become economically favoured.78
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Meeting with Jessika Van Leeuwen (Member of the European Parliament)

4 Nov 2025 · From Bioresources to Bioeconomy

Meeting with Nicolás González Casares (Member of the European Parliament) and Clean Air Task Force, Inc. and Carbon Gap ASBL

4 Nov 2025 · Climate action

Bellona Europa urges mandatory emissions limits across all building lifecycle stages

31 Oct 2025
Topic — EU framework for calculating global warming potential of new buildings by 2030.
Message — The organization requests that all lifecycle stages be covered by mandatory limit values, not left optional to Member States. They propose creating an EU-wide database for generic data and including pre-construction demolition as required. They recommend introducing time-dependent coefficients to reward longer building lifespans over 50 years.1234
Why — This would create lead markets for low-carbon construction products and reduce avoidable blind spots in emissions data.567
Impact — Member States lose flexibility to exclude lifecycle stages from emissions limits and calculations.89
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Bellona Europa urges major boost to EU climate spending

31 Oct 2025
Topic — EU proposal for post-2027 European Competitiveness Fund supporting clean industrial transition.
Message — The organization requests much higher climate spending targets and stronger safeguards. They argue the proposed 26.2 billion clean transition envelope cannot bridge the 400 billion yearly funding gap. They demand investments follow strict climate impact criteria and oppose merging the LIFE Programme into general schemes.123
Why — This would preserve their primary EU funding mechanism and maintain their watchdog role.4
Impact — Fossil fuel industries and companies failing labor standards lose access to subsidies.56
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Meeting with Luca De Carli (Head of Unit Climate Action)

16 Oct 2025 · Revision of the European Climate Law

Bellona Europa urges stronger green procurement rules for EU clean tech

14 Oct 2025
Topic — EU regulation on environmental sustainability requirements for public procurement of net-zero technologies.
Message — The organization requests incentives for low-carbon materials in all net-zero projects, facilitated cross-border procurement, and progressive recyclability targets for wind turbines rising to 95% by 2030. They argue the proposed 70% threshold is unambitious since most turbine mass is already recyclable.1234
Why — This would strengthen markets for European low-carbon products and circular manufacturing.56
Impact — Manufacturers using high-carbon materials and non-circular designs lose competitiveness under stricter requirements.78
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Meeting with César Luena (Member of the European Parliament)

13 Oct 2025 · EU Climate Law and permanent carbon removals

Meeting with Susana Solís Pérez (Member of the European Parliament) and Clean Air Task Force, Inc. and Carbon Gap ASBL

6 Oct 2025 · European Climate Law

Bellona Europa urges strict CBAM carbon price verification rules

25 Sept 2025
Topic — EU rules for recognising carbon prices paid in third countries under CBAM.
Message — The organisation requests that CBAM recognise only carbon prices effectively paid without rebates, discounts, or offsets. They demand transparent monitoring and the exclusion of carbon credits from CBAM certificate deductions.123
Why — This would ensure EU climate standards are not undermined by weaker rules abroad.4
Impact — Third-country producers lose cost advantages from rebates, free allowances, and carbon credits.56
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Bellona urges no delays in phasing out EU carbon credits

25 Sept 2025
Topic — EU rules adjusting carbon border charges based on free emission allowances.
Message — The organization demands the phase-out timeline remain unchanged without extensions. They argue free allowances have delayed industrial transformation for two decades and weakening the transition would jeopardize EU climate goals.123
Why — This would accelerate the carbon price signal driving investments toward their preferred low-carbon technologies.4
Impact — Carbon-intensive industries lose cost advantages from free pollution permits worth billions annually.56
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Bellona Europa urges strict CBAM methodology to drive global climate action

25 Sept 2025
Topic — New EU rules on calculating carbon emissions embedded in imported industrial goods.
Message — The organization requests that CBAM methodology prioritize actual emissions over defaults, include scrap metals and all carbon-intensive precursors like coke and lime, and cover indirect emissions across all sectors with strict renewable electricity criteria. They oppose mass balancing and book-and-claim systems.12345
Why — This would strengthen climate ambition globally and ensure foreign producers face equivalent carbon costs to EU manufacturers.67
Impact — High-carbon producers in third countries lose competitive advantage from lax environmental standards and resource shuffling.89
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Bellona Europa urges EU to set strict global decarbonisation standards

11 Sept 2025
Topic — This initiative sets out the EU's global climate and energy strategy for 2025-2029.
Message — The organization calls for a precise, science-based definition of abated fossil fuels that includes all lifecycle emissions. They advocate for tripling global renewable energy capacity and establishing green industrial partnerships with Africa.123
Why — Stricter global standards would lower Europe's decarbonisation costs and protect its long-term industrial competitiveness.45
Impact — Financial burdens will increase for industries that persist in using fossil fuels rather than transitioning.6
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Bellona Europa Urges New EU Authority for CO2 Infrastructure

11 Sept 2025
Topic — EU consultation on creating competitive markets and transport infrastructure for carbon dioxide.
Message — The organization requests an independent EU authority for CO2 network planning and coordination. They call for non-discriminatory infrastructure access and a cross-border CCUS Network Code.12
Why — A unified regulatory framework would reduce carbon abatement costs and prevent national fragmentation.34
Impact — Infrastructure operators would be prevented from charging excessive tariffs or extracting monopoly rents.56
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Response to European Climate Law amendment

11 Sept 2025

While the reaffirmation of the 90% emission reduction target for 2040 is welcome and necessary, proposed amendments raise concerns about potential loopholes that risk undermining this ambition: the proposed use of international credits after 2036, sectoral flexibility and the possible integration of permanent removals into the EU ETS. These mechanisms could dilute climate action, weaken investment signals and harm the EU credibility ahead of COP30. The proposed 90% target is scientifically sound and strategically essential, albeit only in line with the lower end of scientific recommendations. To make it credible and investable, it must be underpinned by limited and separate contributions for permanent carbon removals and LULUCF. These must reflect each pillars specific risks and potential, with removals governed by strict monitoring, reporting and verification (MRV) standards. Emissions cuts must remain the top priority. The EU should avoid setting a 2035 target that deviates from a pathway to 90% net reductions by 2040. A weak interim target would lower ambition and signal a slowdown in near-term efforts. A 2035 target of at least 72.5% ideally 79% would help ensure the EU stays on track. Frontloading action this decade is essential to stay within the EUs remaining carbon budget, lower overall costs and reduce pressure on future generations. Although details remain vague, the possible introduction of international credits raises major concerns. Changing the scope of the Climate Law from domestic to international risks weakening Europes leadership and accountability. It also sets a problematic global precedent, especially when the credibility of international offsets remains questionable. They must meet strict quality standards and be governed by a robust Monitoring, Reporting and Verification (MRV) system. We, however, do welcome the safeguards: using credits is only a possibility, limited in time and quantity, and should meet high-quality criteria. This should be used only as a last resort measure, and be subject to a dedicated, detailed impact assessment first. The role of CDR must be limited, transparent and well-defined. While CDR will be needed, it must not delay or replace emission reductions. Before any inclusion of CDR in the ETS, the Commission must carry out a full impact assessment, exploring other interaction options beyond direct integration. Only permanent removals with strict MRV should be considered. Importantly, it must not divert attention or funding from the core priority of emissions reductions. A separate permanent removals target is needed, aligned with impact assessments. Sectoral flexibility should be strictly limited. Overperformance in one sector must not justify inaction in another, as this blurs accountability and could delay systemic transformation. The LULUCF sector, in particular, must do its own job with its own 2040 contribution and no cross-sectoral compensation. The ambition should be maintained, while updating its contribution based on current data and potential of EU land sinks. The 2040 target must be ambitious, realistic and enforceable. That means: aligning the 2035 target with 2040, keeping domestic reductions central, establishing separate and limited contributions for LULUCF and CDR, limiting flexibilities and ensuring strong MRV for any additional mechanisms. We have attached our policy briefing, which provides more detailed feedback.
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Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament, Shadow rapporteur)

10 Sept 2025 · 2040 climate target

Bellona Europa urges 90% electric target for corporate fleets

8 Sept 2025
Topic — The consultation explores setting mandatory targets for zero-emission vehicle uptake in corporate fleets.
Message — Bellona proposes a 90% binding electrification target by 2030 for large companies. They also advocate for mandatory green steel procurement and zero-emission requirements for freight shippers.12
Why — The proposal would accelerate the second-hand electric market and lower industrial decarbonization costs.34
Impact — Large shipping companies would be forced to pay higher premiums for zero-emission transport.5
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Bellona Europa opposes expanding ETS state aid without climate reforms

5 Sept 2025
Topic — A consultation on updating state aid rules for indirect ETS electricity costs.
Message — Bellona Europa recommends against adding sectors to the scheme under its current design. They argue that compensation must be restricted to zero-emission electricity to avoid subsidizing fossil fuels. Additionally, they call for stricter earmarking of received aid for climate action.123
Why — This proposal ensures carbon market revenues fund decarbonization rather than supporting fossil power.45
Impact — Carbon-intensive companies would lose indirect subsidies that currently shield them from carbon prices.67
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Bellona Europa urges resilient carbon accounting and LULUCF targets

4 Sept 2025
Topic — The initiative establishes an integrated framework to manage accelerating climate risks across Europe.
Message — Bellona Europa calls for integrating climate risk scenarios into carbon accounting reporting frameworks. They also advocate for a specific resilience target for the forestry sector.12
Why — This would ensure long-term reliability of removals and strengthen carbon market credibility.3
Impact — Advocates for deregulation lose the ability to lower monitoring and environmental standards.45
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Meeting with Niels Fuglsang (Member of the European Parliament, Rapporteur for opinion)

29 Aug 2025 · Revision of climate law

Response to European grid package

5 Aug 2025

Bellona's feedback can be found in the file attached.
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Bellona Europa urges ports to lead industrial decarbonisation efforts

28 Jul 2025
Topic — This consultation seeks input on shaping a comprehensive strategy for European port development.
Message — The organization argues ports should serve as hubs for carbon capture and industrial decarbonisation. They request the EU align port strategy with carbon management laws and fund renewable energy infrastructure. Port authorities should also use procurement power to boost demand for low-carbon materials.123
Why — This would accelerate carbon capture deployment and secure funding for green port infrastructure.45
Impact — High-emission shipping firms may face higher costs as port fees incorporate environmental criteria.6
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Response to Revision of the Standardisation Regulation

16 Jul 2025

Please find attached Bellona's feedback on the revision of the Standardisation Regulation. We appreciate the opportunity to contribute our views on this matter.
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Meeting with Aura Salla (Member of the European Parliament)

15 Jul 2025 · Clean Industrial Deal, CSS

Bellona Europa demands stricter emission rules and electrification focus

8 Jul 2025
Topic — The European Commission is evaluating the performance and operations of the Innovation Fund.
Message — The group wants to end the zero-emission assumption for electricity usage. They suggest excluding fossil carbon capture and supporting industrial clusters for greater impact.123
Why — Stricter criteria would ensure funding targets high-impact projects that achieve genuine decarbonization.4
Impact — Fossil fuel industries would lose subsidies for carbon capture projects that lack permanent storage.5
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Bellona Europa Urges Phased Integration of Carbon Removals

8 Jul 2025
Topic — This consultation reviews the EU Emissions Trading System and Market Stability Reserve framework.
Message — Bellona requests a phased approach where only permanent carbon removals are eventually included. They demand separate targets for reductions and removals while setting strict quantity limits. They also urge an end to the carbon neutral assumption for biomass.123
Why — This strategy ensures climate policy remains focused on permanent solutions rather than risky offsets.45
Impact — Heavy industrial emitters lose the ability to use cheap, impermanent land-based offsets for compliance.67
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Meeting with Kurt Vandenberghe (Director-General Climate Action) and Transport and Environment (European Federation for Transport and Environment) and

13 May 2025 · Clean Industrial Deal to deliver a Joint Decarbonisation and Competitiveness Roadmap

Bellona Europa urges strict CO2 storage accountability for producers

16 Apr 2025
Topic — Regulation defining how oil and gas companies contribute to CO2 injection capacity.
Message — The organization demands a finalized list of obligated entities to ensure detailed planning by 2025. They advocate for robust reporting standards and mandatory penalties for non-compliance.12
Why — This ensures the deployment of infrastructure critical to Bellona's climate and industrial decarbonization goals.3
Impact — Large oil and gas companies lose the ability to focus solely on high-profit extraction activities.4
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Meeting with Tiemo Wölken (Member of the European Parliament) and Carbon Market Watch

10 Apr 2025 · UNFCCC Art. 6 and the 2040 target (staff level)

Bellona Europa warns Omnibus proposal undermines EU climate credibility

26 Mar 2025
Topic — This initiative proposes simplifying corporate reporting requirements for the EU Sustainable Finance Taxonomy.
Message — Bellona Europa opposes exempting smaller companies from reporting and rejects the new 10% materiality threshold. They demand that modifications remain grounded in robust scientific evidence.123
Why — Preserving strict rules maintains the relevance and impact of the NGO's previous policy work.45
Impact — Smaller firms would lose the administrative relief and cost savings promised by the simplification.6
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Meeting with Anne-Maud Orlinski (Cabinet of Commissioner Dan Jørgensen)

17 Mar 2025 · Exchange of views on policy priorities as a follow up of the Clean Industrial Deal and the Affordable Energy Action Plan

Meeting with Dario Tamburrano (Member of the European Parliament, Shadow rapporteur) and TotalEnergies SE and Terna spa

12 Mar 2025 · Reti elettriche

Meeting with Giorgio Gori (Member of the European Parliament, Rapporteur)

4 Mar 2025 · Energy intensive industries

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Bellona Europa appreciates the opportunity to provide input on the proposed amendments to the Annex, which lists the final products and specific components primarily used for the production of net-zero technologies. We recognize the importance of ensuring a comprehensive and precise categorization of technologies and their associated components to support the rapid deployment of net-zero technologies across Europe to enable the EU to reach its net-zero emission by 2050 goals. In the attached file, we provide our recommendations for modifications and additions to the Annex, structured by net-zero strategic technology categories.
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Bellona Europa urges kelp restoration and mandatory marine data sharing

17 Feb 2025
Topic — The European Oceans Pact aims to unify EU policies for marine conservation and blue economy.
Message — Bellona calls for mapping and restoring kelp forests while expanding low-trophic aquaculture. They request a framework for mandatory data sharing from industrial impact assessments to improve marine governance.12
Why — This would promote the NGO's preferred circular bioeconomy solutions and enhance climate mitigation efforts.34
Impact — Industrial maritime operators face higher costs from mandatory data sharing and stricter discharge rules.56
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Meeting with Jeannette Baljeu (Member of the European Parliament)

12 Feb 2025 · CCS

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

5 Dec 2024 · Green industry and energy policy

Meeting with Niels Flemming Hansen (Member of the European Parliament)

2 Dec 2024 · Priorities for the mandate

Bellona Europa Urges Linking Energy Security with Climate Action

26 Nov 2024
Topic — The Commission is evaluating the EU's energy security framework following the recent energy crisis.
Message — The organization calls for prioritizing renewable energy targets and accelerating electrification to reduce reliance on imported fossil fuels. They advocate for boosting investment in cross-border infrastructure and energy storage to enhance system flexibility.123
Why — Implementing these changes would align EU energy policy with the organization's climate-focused environmental mission.45
Impact — External fossil fuel suppliers would lose market share as Europe reduces its import dependency.67
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Meeting with Karin Karlsbro (Member of the European Parliament)

21 Nov 2024 · Energiomställningen

Meeting with Stine Bosse (Member of the European Parliament)

21 Nov 2024 · European climate and energy policy

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

18 Nov 2024 · Physical meeting - CBAM, COP29 and Carbon Pricing

Bellona Europa urges stricter lifecycle standards for low-carbon fuels

25 Oct 2024
Topic — This consultation defines the methodology for calculating lifecycle greenhouse gas emissions of low-carbon fuels.
Message — The organization calls for a dynamically decreasing greenhouse gas threshold to drive continuous improvement in carbon capture performance. They demand more conservative default values for methane intensity and the inclusion of midstream transport emissions. They also advocate for hourly emissions accounting to ensure hydrogen production uses truly clean electricity.123
Why — This ensures the low-carbon label is reserved for fuels that provide genuine climate benefits.4
Impact — Fossil fuel suppliers with high upstream methane leakage may be excluded from the market.5
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Meeting with Ana Vasconcelos (Member of the European Parliament)

4 Oct 2024 · Restorative carbon negative society

Meeting with Sofie Eriksson (Member of the European Parliament)

2 Oct 2024 · Utsläppsmål och framtidens politik i ITRE-utskottet.

Meeting with Bruno Tobback (Member of the European Parliament)

1 Oct 2024 · Climate Action Conference 2024

Response to Ex-post evaluation of the Connecting Europe Facility 2014-2020

24 Sept 2024

The Connecting Europe Facility (CEF) plays a crucial role in supporting the development of interconnectors, a key infrastructure for achieving a well-integrated and resilient energy system across the European Union. Interconnectors, which link energy grids between EU Member States, are vital for enhancing the cross-border exchange of renewable electricity. This helps to balance supply and demand, facilitates energy trade, and improves the overall stability and security of the energy supply within the EU. Given Europe's ambitious decarbonisation targets, expanding interconnector infrastructure is more critical than ever. As Projects of Common Interest (PCIs), interconnectors are eligible for significant funding from the CEF. This support has enabled the development of essential interconnection projects, which, in turn, contribute to the EU's energy transition by ensuring that renewable energy sources, such as wind and solar power, can be efficiently integrated into the grid. From a European perspective, the urgent need to ramp up the installation of interconnectors cannot be overstated. Interconnectors play a crucial role in facilitating the flow of renewable energy across borders, thereby significantly enhancing the flexibility of the energy system. By enabling the exchange of renewable electricity between countries, these projects help to stabilise energy supplies, mitigating the risks associated with fluctuations in renewable output. This flexibility is particularly crucial as Europe continues to increase its share of renewables in the energy mix, given the inherent variability of wind and solar power. The Connecting Europe Facility (CEF) fund also plays a role in advancing the EU's cross-border hydrogen infrastructure by providing strategic and financial support to Projects of Common Interest (PCI). However, for these funds to have the most significant impact, they must be allocated with precision, contributing to the decarbonisation of the entire system and not just to foster the development of a hydrogen economy. It is particularly important to showcase the potentially adverse effects of large-scale hydrogen production on a rather carbon-intensive electricity grid. Investments should be directed towards no-regret hydrogen corridors that maximise efficiency and ensure security of supply while seamlessly integrating with other energy sources. By taking a systems-based approach to planning, the CEF can ensure that its funds are used for targeted hydrogen projects that deliver long-term sustainability and optimise the overall energy landscape in Europe. CEF has been instrumental in initiating the deployment of CO2 networks (transport and storage infrastructure) for Carbon Capture and Storage (CCS). Recognised by the European Commission in the 2024 Industrial Carbon Management Strategy (ICMS) as crucial for achieving 2040 and 2050 climate targets, CCS has become a necessity, and is urgently needed to enable full industrial decarbonisation. To do so, the development of a CO transport and storage value chain requires substantial upfront investments in cross-border infrastructure. It necessitates de-risking and financing mechanisms at both EU and national levels, given the lack of sufficiently strong carbon pricing signal that would justify CCS deployment on a commercial basis. CEF support for CO2 networks is driving innovation and economies of scale, ultimately fostering a self-sufficient market for industrial decarbonisation. Some of the front-running CCS projects are already benefitting from CEF funding for their feasibility and FEED studies, and for the construction of the CO2 handling infrastructure, thus gaining experience and enabling knowledge sharing with other CCS projects. This infrastructure is also crucial to enable the necessary, but limited, deployment of Carbon Dioxide Removals (CDR) in line with the EUs aim of going beyond climate neutrality, towards net negative emissions after 2050.
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Meeting with Bruno Gonçalves (Member of the European Parliament)

12 Sept 2024 · ITRE policies

Bellona Europa urges stricter monitoring for carbon transport and aviation

29 Jul 2024
Topic — This initiative updates the rules for the monitoring and reporting of greenhouse gas emissions.
Message — The organization calls for CO2 transport for utilization to be on the same footing as geological storage. They also request implementing monitoring schemes for all flights departing from the EEA.12
Why — Enhanced data collection would help the NGO advocate for penalising all emissions that reach the atmosphere.34
Impact — Aviation and carbon utilization companies would face higher compliance costs and new reporting requirements.5
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Meeting with Tiemo Wölken (Member of the European Parliament)

25 Jul 2024 · Climate Policies in the new mandate

Response to Permanent storage of EU ETS emissions through carbon capture and utilisation

16 Jul 2024

Bellona Europa welcomes the Commissions initiative in the upcoming Delegated Act to identify the products which can be considered to permanently chemically bind greenhouse gases, specifically captured CO2. Ultimately, installations generating CO2 will not need to surrender allowances only if they can prove that the CO2 will not be entering the atmosphere further down the value chain. Bellona Europa believes that identifying the handful of products that permanently store CO2 in line with the ETS Directive (EU) 2023/959 is crucial to ensure the climate integrity of Industrial Carbon Management solutions such as CCS and CCU as well as the accurate accounting of the flow of CO2. It also allows for differentiation between CCU use cases with concrete climate change mitigation potential and those that are primarily commercial applications with unclear climate change mitigation potential. According to the Directive, ETS installations must surrender emission allowances to account for indirectly emitted CO2 unless the CO2 is permanently geologically stored or the CO2 is considered to have been captured and utilised in such a way that they have become permanently chemically bound in a product so that they do not enter the atmosphere under normal use, including any normal activity taking place after the end of the life of the product. The Commission deserves praise for establishing robust and scientifically sound criteria, effectively minimizing the possibility of loopholes that could lead to unaccounted rerelease of CO2 captured from ETS installations which could have resulted in the laundering of CO2 emissions out of the ETS framework. Bellona Europa also supports the use of an exclusive whitelist of activities and the review process being based on relevant technological developments and that the burden of proof for meeting the stringent requirements of the Directive and the Delegated Act rests with those submitting requests to include new products on the list. ** Carbon Capture and Utilisation entails the capture of carbon, usually from fossil industrial flue gases, and its subsequent utilisation whereby additional energy is used to convert the carbon into a product or feedstock. It must be noted that if CCU processes do not permanently chemically bound CO2 and it is not prevented from reaching the atmosphere, the climate benefit of capturing the CO2 is simply to delay emissions. The delayed emissions can be in the order of weeks, months, or decades, and may also occur at a time when the climate system is more unstable than it is today. Since CO2 accumulates in the atmosphere, and subsequently causes climate change, there is very little value in simply delaying an emission if the end result is to continue to contribute to higher atmospheric CO2 concentrations. Given the questionable climate benefits of most applications of CCU, as well as its large energy requirements, its deployment and incentive structures should be targeted and well managed respectively to prevent perverse outcomes. Please find further recommendations in our attached policy brief There and back again: Navigating the climate impacts of CO2 use.
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Response to Amendment of the climate reporting implementing regulation to reflect the Fit for 55 outcomes

11 Apr 2024

Bellona Europa welcomes the proposed amendments to Implementing Regulation 2020/1208, reflecting the outcomes of the Fit for 55 package. In particular, we welcome the modifications to Article 5 and Annex II of the Regulation, referring to the reporting on the use of the ETS revenues which needed to be aligned with the revised ETS Directive. The content of this consultation response is based on an analysis conducted by Bellona Europa on the issue and attached to this feedback. The revised ETS Directive rightly foresees that the entirety of the revenues collected by the generated from the auctioning of ETS allowances must be spent towards climate action, some pitfalls can be identified: 1) The categories which define what is meant by climate action are too vague and broad, putting on the same level solutions with very different degrees of prioritisation and impact in the fight against climate change. 2)The exemption of revenues used for compensation of indirect carbon costs diverts up to one fourth of the revenues collected from climate action expenses and might obstacle the overall EU climate objectives. 3) The consequences for uncompliant Member States remain unclear, creating a risk of lack of accountability and undermining the reform. 4) Clear spending categories and definitions need to be set in the reporting, for Member States to be held accountable for their actions. While the review of the Implementing Regulation 2020/1208 aims to address the fourth point listed above, the other points remain gateways for dangerous loopholes that might undermine the overall EU climate targets. Nonetheless, to ensure that ETS revenues are actually spent on climate action, it is crucial that the template for reporting on the use of such revenues is designed in a way that is simple, does not result in double regulation, and is standardised across all Member States, leaving no room for interpretation. In light of the above, our overall assessment of the suggested amendments to Regulation 2020/1208 is mainly positive. However, the following points must be considered: In Article 5, a clearer definition of not sufficiently detailed should be included. This is crucial to provide clarity to Member States, and avoid inconsistencies among the different reports, which must be similar and comparable. The definition should be clear enough to ensure that the projects reported as financed by ETS revenues do not result in investments towards fossil fuels, in disguise. In Annex I, table 3, the reference to the agency tasked with implementing the project has been removed. This might result in lack of accountability for Member States in case the information provided is not sufficiently detailed or it contravenes the spending categories outlined in the revised ETS Directive. Member States need to able to track responsibilities and facilitate corrective measures. In Annex I, table 3 -together with ensuring the project is consistent with NECPs and JTPs- consistency with the EU 2030 and 2040 climate targets should be reported. This would ensure coherent expenditures among Member States. While the differentiation made between disbursed amount and committed amount is necessary, this must align with ensuring that long-term plans are accountable, and expenditures are actually allocated in climate credible project, preventing diversions at a later time. In Annex I, table 4, a qualitative description of the project should be provided regardless of its geographical destination. This is coherent with table 3, allowing for public scrutiny to assess its consistency with EU and global climate targets. In sum, reporting the use of ETS revenues should be designed with a focus on the accountability of Member States action, transparency of the information provided and consistency among Member States. Moreover, no room can be left for loopholes that might undermine the overall climate objectives of the EU.
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

Bellona welcomes the Commissions initiative to provide guidance on designating renewable acceleration areas. The proposal holds significant promise in accelerating the deployment of renewable energy to meet the EU targets. The renewable acceleration areas outlined in Article 15c of RED hold significant promise as instrumental mechanisms for expediting the deployment of renewable energy sources within the EU. Renewables are the cornerstone of the energy transition and, as they are produced locally, can vastly contribute to increased energy security by freeing Europe from dependence on imported fossil fuels. However, this cannot be done at the expense of the environment, thus, acceleration areas should be identified as areas with low environmental risks. This will reduce investment risk. and public opposition, together with early involvement of affected communities. We emphasise the critical need to adopt a holistic approach when it comes to this planning, taking into account environmental, societal and infrastructural/technical considerations, particularly regarding the necessary grid infrastructure. We appreciate that areas for grid infrastructure are tackled in REDs Article 15e, in particular, point (c) stresses that we should ensure synergies with the designation of renewables acceleration areas. Therefore, renewables acceleration areas should be identified with careful consideration of the existing and anticipated grid infrastructure, incentivising its buildout if this is not available. Its imperative to recognise that the success of these areas hinges not only on the suitability for renewable energy projects but also on the availability of appropriate grid infrastructure to support their integration into the energy system and the delivery of the electricity to the final consumers. The potential benefits of acceleration areas for wind and solar projects may be severely constrained if adequate grid infrastructure is not deployed. Therefore, while Member States can designate renewable acceleration areas for various renewable energy technologies, the focus must also encompass the associated grid infrastructure and storage buildout. This ensures that the acceleration areas are not merely isolated pockets for renewable energy deployment but integral components of a cohesive and efficient energy system. We stress that the designation of renewables acceleration areas should culminate in a coordinated effort that develops the entire energy system. This includes building the necessary grid and storage infrastructure once the viability of wind and solar projects within these areas is assessed. Failure to do so may undermine the effectiveness of the acceleration areas in achieving their objectives. Projects face operational challenges and economic viability issues without sufficient transmission and distribution capacity, managing intermittency, and integrating renewable energy. Addressing grid infrastructure needs is essential to maximise the potential of acceleration areas and achieve the EU 2030 renewable energy targets. Furthermore, finding a delicate balance between harmonisation at higher levels and flexibility at the local level is key in ensuring the effectiveness of the methodology and criteria used for designating favourable areas and renewable acceleration zones. Recognising the importance of national or higher-level guidance to promote consistency and coherence in decision-making processes is essential. However, embracing is equally crucial for fostering adaptability and responsiveness to diverse regional contexts. In conclusion, we urge thorough consideration of grid infrastructure and storage requirements when designating renewable acceleration areas. By adopting a holistic approach that addresses renewable energy deployment, grid integration needs and environmental protection, Member States can maximise the impact of these areas in accelerating the transition to a sustainable energy future.
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Meeting with Kadri Simson (Commissioner) and

9 Jan 2024 · Meeting with CCS Europe members on CCS strategy.

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

9 Dec 2023 · Physical meeting - Speaker at the UNFCCC COP 28 side-event “What is the road ahead for interconnected carbon pricing systems and CBAMS?”

Meeting with Michael Bloss (Member of the European Parliament) and Air Products

9 Dec 2023 · Hydrogen Standards

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur) and Clean Air Task Force, Inc. and Carbon Gap ASBL

10 Oct 2023 · Carbon Removals (Staff level)

Meeting with Tom Berendsen (Member of the European Parliament)

21 Sept 2023 · Host of event “Decarbonising hard-to-abate industries in Northwest Europe – How CCS can help achieve European climate goals”

Response to Carbon capture utilisation and storage deployment

31 Aug 2023

Bellona Europa welcomes the opportunity to respond to the Call for Evidence for the Industrial Carbon Management Strategy, as published on the 9th of June 2023 open for 12 weeks. The following response tthe call for evidence should be viewed as accompanying and highlighting additional points and priorities as outlined in the already submitted response from Bellona Europa to the Open Public Consultation on the Industrial Carbon Management Strategy. We also refer to other relevant past submission by Bellona Europa, including for the consultation on restoring sustainable carbon cycles from 202. 2023 will see the 3rd annual CCUS Forum organised by the European Commission. Bellona Europa has actively participated in the WGs on Public Perception, Industrial Partnership, and as a Chair to the WG on CO Infrastructure. Bellona therefore urge that the recommendations from these three WGs forms the basis for the upcoming Industrial Carbon Management Strategy. As outlined in a recent letter by several stakeholders including Bellona Europa to Executive Vice-President Frans Timmermans and Commissioner Kadri Simson, it is of crucial importance that this strategy is published in a timely manner, sticking to the planned timeline of publication before the end of the year as opposed to delaying the strategy or tying it to other ongoing policy initiatives. As already outlined by Bellona Europa several times as part of the work of the CCUS Forum, as well as through Bellona Europas role in the Zero Emissions Platform (ZEP), there is a need to address the frequent conflation of the terms CCS, CCU and CDR, as outlined below. This was also outlined by Bellona Europa in its feedback to the Net-Zero Industry Act (NZIA). It is of crucial importance that the upcoming Industrial Carbon Management Strategy builds on ongoing efforts such as the NZIA, in particular in strengthening the work to establish CO injection capacity targets for the EU in a timely manner, and ensure appropriate responsibility on development of such storage sites on Oil and Gas producers. As highlighted by Bellona, IOGP, CATF, SINTEF, CCSA and ZEP in a recently published letter, there is broad agreement on such a responsibility on oil and gas producers, as long as circumstances outside of their control are addressed and estimated by the European Commission in an appropriate manner. While it is crucial to define targets for available storage capacity, it is also important to ensure that a CO storage target does not become an end goal in itself, risking the creation of perverse incentives and/or failing to encourage other means of decarbonization where possible. We find that an injection capacity target, evaluated alongside expected needs and supply of CO, correctly balances these considerations. No Net-Zero without Carbon Capture and Storage, status as public good. Nearly all climate change modelling scenarios highlight that CO capture, transport and storage, from both fossil and non-fossil sources, will play a key role in reaching climate neutrality at both the EU and global levels. While the technology has existed for decades, a market has not materialised. This is the result of persisting market failures. Both EU and national policy instruments can play an important role in addressing such market failures, supporting the development and deployment of CCS in Europe. But a clear forward-looking strategy is needed to ensure CCS development and contribution to a green and just transition, showing a clear decarbonisation pathway for harder-to-abate heavy industry which cannot decarbonise in other ways. While of crucial importance, CCS is no silver bullet. And as outlined in Bellonas recently published CCS ladder together with E3G, targeted use is key.
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Bellona Europa Urges Broad CO2 Transport Recognition in MRR

23 Aug 2023
Topic — This consultation updates the rules for monitoring and reporting greenhouse gas emissions.
Message — Bellona Europa requests that the regulation recognise all transport modalities, including ships and trucks. The definition of transport network must include pipelines, ship, rail, truck, and barges. Operators must provide detailed data on fuel types and their full climate impact.123
Why — Installations can subtract CO2 transported via any modality from their total emissions.4
Impact — Pipeline operators lose their exclusive status as the only recognized CO2 transport method.5
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Bellona Europa urges 90% emissions cut for 2040 target

23 Jun 2023
Topic — The EU is establishing a 2040 climate target to achieve climate neutrality by 2050.
Message — The organization recommends adopting at least a 90% net emission reduction target by 2040. They call for separate targets for emission reductions and carbon removals to ensure transparency and permanence. Additionally, they advocate for prioritizing direct electrification and permanent geological storage of captured CO2.123
Why — Establishing clear targets and infrastructure support would reduce investment risks for industrial decarbonisation.4
Impact — Industries using biological offsets would lose the ability to compensate for fossil-based emissions.5
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Meeting with Ville Niinistö (Member of the European Parliament)

9 Jun 2023 · NZIA

Bellona Europa Demands Strict Conditions for Net-Zero Industrial Support

24 May 2023
Topic — The consultation gathers feedback on the proposed EU Net Zero Industry Act regulation.
Message — The organization requests strict storage injection targets that exclude oil recovery and require electrolysers to use renewable energy. They also seek higher sustainability weights in public contracts.123
Why — Tighter rules would prevent public support from being wasted on technologies that increase emissions.4
Impact — Fossil fuel companies would bear the financial burden and risk penalties for missing targets.5
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Bellona Europa calls for efficient, consumer-focused electricity market reform

23 May 2023
Topic — Revision of the European Union's electricity market design to improve resilience and sustainability.
Message — Bellona suggests earmarking contract revenues for energy efficiency projects for vulnerable consumers. They seek binding national storage targets and faster grid permits for electricity users. They also want technology selection based on efficiency rather than just market price.123
Why — This would accelerate the energy transition and improve financial protections for low-income households.45
Impact — Inefficient energy producers and fossil gas plants would lose their current market advantages.6
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Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur) and Clean Air Task Force, Inc. and Carbon Gap ASBL

23 May 2023 · Differentiation between different kind of Carbon Removals (staff level)

Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and

22 May 2023 · Net-Zero Industry Act Stakeholder Hearing

Bellona Europa Urges EU to Maintain High Taxonomy Standards

3 May 2023
Topic — This initiative establishes a classification system for investments contributing to EU environmental objectives.
Message — Bellona Europa argues that substantial contribution criteria must set a golden standard and exceed existing legal requirements. They request that technical screening criteria align with recommendations from the Platform on Sustainable Finance. The group calls for restoring higher recycling targets and mandating third-party verification for building global warming potential.123
Why — These changes would protect the taxonomy's credibility and ensure it remains a useful environmental tool.45
Impact — Biobased plastic producers and developers face higher hurdles to prove their activities are truly sustainable.67
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans) and

29 Mar 2023 · EU-Norway energy cooperation

Response to Carbon Removal Certification

23 Mar 2023

Bellona Europa is an independent, non-profit organisation that meets environmental and climate challenges head on. We are solutions-oriented and have a comprehensive and cross-sectoral approach to assess the economics, climate impacts and technical feasibility of necessary climate actions. To do this, we work with civil society, academia, governments, institutions, and industries. Please find a summary of our position paper below. The full paper is attached to this response. * DO NOT INCLUDE REDUCTIONS IN THE DEFINITION OF REMOVALS The fundamental purpose of the Carbon Removal Certification Framework should be the certification of carbon removals. Critically, emission reductions must never be certified as removals, as they are fundamentally distinct activities: Removals decrease atmospheric greenhouse gases where reductions prevent further increase in atmospheric greenhouse gases. Emission reductions and other non-removal activities must be supported by separate instruments, such as the ETS, the Common Agricultural Policy, and the forthcoming Nature Restoration Law. DEFINE REMOVALS AS THE PHYSICAL NET DECREASE IN ATMOSPHERIC GREENHOUSE GASES To ensure that certified removals result in a decrease of atmospheric greenhouse gases, CRCF should define carbon removal as the permanent storage of atmospheric CO2 in excess of all direct and indirect greenhouse gas emissions associated with the removal activity. HOLD ALL CARBON REMOVAL ACTIVITIES TO THE SAME STANDARDS The CRCF should be neutral in terms of what carbon removal activities can issue certificates, with the quality of the removals ensured by holding all carbon removal activities to the same strict standards of quantifiability, permanence, liability, and sustainability. ALL REMOVALS MUST BE MEASURABLE AND ACCOUNT FOR ALL ASSOCIATED EMISSIONS Quantification should measure the amount of carbon physically extracted from the atmosphere and permanently stored then subtract all direct and indirect emissions associated with the removal activity to determine the net removal that occurs. Only the net removal should be eligible for crediting of any sort. Emission reduction activities should never be included in removal quantification. It must also be possible to verify that a removal physically occurred and to monitor the stored carbon. If a removal cannot be effectively quantified or monitored, it must not be certified as a removal. ALL REMOVALS MUST BE PERMANENT, WHICH REQUIRES PERMANENT LIABILITY Ensuring the permanence of all removal is critical for preventing the risk of a carbon timebomb, where insecurely stored carbon could be rapidly re-emitted at an unexpected point in time (e.g., large scale forest dieback) that we may or may not be equipped to deal with. Different removal activities have different risks of reversal and different requirements to maintain and monitor the removal. As a removal requires permanent storage to serve its intended purpose of decreasing atmospheric greenhouse gases, liability must also include the obligation to rectify any reversal with a removal of equal or greater quality. The CRCF should address general principles of the chain of perpetual liability, such as to monitor the removal, prevent a reversal, and to rectify any reversals that do occur. REMOVALS MUST ADHERE TO SUSTAINABILITY STANDARDS Strong criteria for the use of land and biomass for carbon removal will also support the integrity of land-based removal by promoting resilient ecosystems, reducing the risk of reversal while supporting other sustainable development goals. In the case of engineered removals, direct and indirect impacts of land, energy, and water use must be explicitly evaluated. The CRCF has the potential to set the stage for standards of carbon removal around the world. It is vital that it defines removal unambiguously and holds removal activities to a high standard based on physical science. And it must ensure that any certificatio
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Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur) and Carbon Market Watch

8 Feb 2023 · Union certification framework for carbon removals

Response to European Critical Raw Materials Act

25 Nov 2022

Reduced demand and increased circularity should be the first priorities in covering the need for critical raw materials. Policies to reduce demand can include setting binding material footprint reduction targets, as described in the consultation response from the EEB. There is also a strong need to increase circularity for many CRMs. In order to move these materials upward in the Waste Hierarchy, the CRMA must: Ensure that circularity measures apply to all products containing CRMs including imports. Update the EU Extractive Waste Directive to strengthen exploration and documentation of CRMs in secondary deposits and waste streams, including that Member States create an open database reporting data on extractive waste facilities. Set product design requirements, including on product longevity and recycled content. Increase support for EU research and innovation funding on recycling, substitution and material recovery technologies for CRMs. More sustainable mining practices in Europe are key to a more sustainable supply of critical raw materials. The CRMA should scale up investment and action on the following measures: Underground mining should be incentivised as opposed to open-pit mining. Alternative mining practices, such as geothermal mining. Avoiding the use of hazardous chemicals. Electrification of mining equipment should be supported to decarbonise the sector. There have been rapid developments in the construction sector, where the availability of zero emissions equipment has increased greatly over the last few years. A similar development should be encouraged for the mining sector. Circular policies should focus on creating a market for mining waste. There is a large potential for utilisation. For instance, the company Saferock has developed technology for producing a low-carbon alternative to Portland cement based on tailings from the Titania mine in Norway. All seabed mining activity should be avoided until the risks are fully understood. There are large knowledge gaps regarding deep-sea ecosystems, and both exploration and extraction activity on the seabed would risk causing large and irreversible damage. Seabed mining should not be supported in any way until the risks are fully understood this would be a breach of the precautionary principle set out in article 191 of the Treaty on the Functioning of the European Union. A range of actors including the United Nations Environment Programme, the World Economic Forum, and the High-level Panel for a Sustainable Ocean Economy, have concluded that there is a need for greater knowledge of the environmental impacts before seabed mining can be properly assessed. The call for a moratorium on deep-sea mining has been signed by actors such as Google, BMW, Philips, Samsung SDI, Volvo, Volkswagen, Renault Group, and Northvolt. Mining activities will almost always have adverse environmental impacts. Advocates for seabed mining often use the impacts from traditional mining as an argument to support seabed mining. Such claims are fundamentally flawed however, given the major knowledge gaps. The environmental impacts from seabed mining can potentially be much worse than those related to mining on land. Raw materials are key for the green transition, but seabed minerals will not be able to contribute. The largest increase in the demand for raw materials related to the green transition is expected during the next 10-15 years. Today, it normally takes more than 10 years to open a mine on land, where the knowledge base already exists. In order to responsibly open a mining project on the seabed, significantly more time will have to be expected to close the knowledge gaps related to deep-sea ecosystems as well as those related to methods and technology for extracting and processing. Seabed minerals will arrive too late for the green transition or not at all.
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Meeting with Ville Niinistö (Member of the European Parliament)

15 Nov 2022 · COP 27 and Carbon Removals

Response to Regulation on REPowerEU chapters

20 Jul 2022

Bellona Europa welcomes the ongoing efforts by the European Commission and the opportunity to provide recommendations on the REPowerEU update to the Recovery and Resilience plans. We welcome the REPowerEU initiative of the EU to reduce its dependence on fossil gas, finally moving towards both climate goals and energy security. Together with other decarbonisation strategies, REPowerEU should be designed to kickstart additional renewable energy deployment and focus on energy efficiency to create a more resilient and clean energy system. Our key recommendations are the following: • The fossil fuel focus needs to be on a strictly temporary basis. No additional infrastructure financing and development is needed. • Boosting energy efficiency and renewable generation is key. Inefficient uses of energy and electricity cannot be prioritised. • Cross-border infrastructure is crucial, both for energy system optimisation and other decarbonisation technologies. • Accelerated re-qualification of the workforce is needed and welcome to ensure that the transition to a clean and resilient energy system is succesful. • The Do No Significant Harm (DNSH) criteria should not be circumvented. The attached document outlines our recommendations on the contribution of Recovery and Resilience Plans to the specific REPowerEU objectives outlined in Article 21c in further detail.
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Bellona Europa pushes for ambitious renewable targets and permitting reform

19 Jul 2022
Topic — Guidance for speeding up renewable energy permitting and Power Purchase Agreements.
Message — Bellona supports accelerated permitting while calling for national binding targets for energy efficiency and mandatory rooftop solar on all buildings. They also recommend using EU climate funding to address staffing shortages in national permitting authorities.123
Why — Faster permitting reduces investment risks and accelerates the climate solutions Bellona promotes.4
Impact — Provisions like automatic approval for projects could potentially harm local ecosystems and nature conservation.5
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Response to Union guidelines for the development of the TEN-T network amended proposal

8 Jul 2022

Please see attached response to call for evidence outlining the importance of includling multiple modalities transport CO2 to storage in the TEN-T Regulation. Necessary also to align with TEN-T Article 5.1(f) calling for synergies with the TEn-E Regulation, and instrumental for the green and just transition.
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Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur)

6 Jul 2022 · TEN-T (Staff Level)

Bellona Europa demands stricter carbon accounting for renewable fuels

17 Jun 2022
Topic — Standardizing the greenhouse gas emission savings methodology for recycled and renewable transport fuels.
Message — Bellona Europa requests the methodology reflect the fuels' entire carbon intensity and prevent double counting. They demand fossil carbon be differentiated from atmospheric sources to ensure real emission reductions.12
Why — This ensures that renewable fuel production supports genuine climate targets and additional green energy.3
Impact — Early-stage hydrogen projects would lose their permanent exemption from requirements to add renewable capacity.4
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Clean Air Task Force, Inc.

22 Apr 2022 · Exchange of views on CCUS

Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur)

21 Apr 2022 · Gas storage regulation

Bellona Europa urges strict gas definitions to avoid fossil lock-in

12 Apr 2022
Topic — EU consultation on adapting gas market rules for renewable and low-carbon gases.
Message — Bellona Europa demands clear, precise definitions for renewable and low-carbon gases. They want to remove hydrogen blending targets to prioritize essential industrial sectors.123
Why — This avoids wasting resources on infrastructure that is not fit for decarbonization.4
Impact — Fossil gas companies lose the ability to justify new infrastructure through blending.5
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Response to Revision of EU rules on Gas

12 Apr 2022

The current proposal from the European Commission fails to free Europe from a fossil lock-in. This has become all the more clear with the release of the REPowerEU and a renewed dedication to reducing Europe’s dependency on fossil gas. A main point of contention is the package’s reliance on so-called “renewable gases” and “lowcarbon gases” - currently still undefined in the Regulation and in hydrogen and ill-defined in the Directive. To reach its climate targets by 2030 and 2050, the EU increasingly rely on both low-carbon and renewable gases. The current lack of a climate framework and sustainability criteria for these gases draws into question their contribution, if any, to climate change mitigation. The package also fails to address one of the most critical issues: the targeted use of low-carbon and renewable gases. These gases will remain a limited feedstock, and their use should be targeted, and limited, to those sectors that cannot otherwise decarbonise - such as the production of fertilisers and long-distance shipping. To decarbonise, these sectors need a pure feedstock. Providing them with blended hydrogen through fossil gas pipelines, definitely characterised by not being a pure feedstock, won’t contribute to decarbonisation. Blended hydrogen risks rather than being used in sectors that could be otherwise decarbonised – such as home heating. Using blended hydrogen in these sectors won’t provide any substantial decarbonisation due to the scale needed and would in fact be an inefficient use of a precious resource: low-carbon and renewable gasses. Additionally, blending justifies continued investment into fossil gas infrastucture under the guise of a potential shift to hydrogen in the future. This justification does not take into account that such a shift is not only unlikely to take place due to high costs and energy inefficiencies, it also requires dedicated hydrogen infrastructure. With dedicated hydrogen infrastructure being different from the fossil gas infrastructure in use with blending, blending is not a necessary stepping-stone in the direction of a decarbonised gas grid. Investments into fossil gas infrastructure justified by blending as such comes at the direct expense of investments into no-regret dedicated hydrogen infrastructure in industrial clusters. Moreover, if Europe used all its electricity to produce hydrogen, it would only be able to substitute 45% of the current European fossil gas demand. It is safe to assume that there would never be enough renewable and low-carbon gases to fully replace the fossil gas currently filling the EU gas grid. The promised full shift from blending to a fully decarbonised gas grid would simply not happen. Investing in the current gas grid that is ‘hydrogen-ready’, with blending as a prioritised stepping-stone, is thus a waste of resources for an asset that is not fit to deliver a decarbonised world. As our analysis of REPowerEU from the 15th of March shows, electricity use must be prioritised for direct electrification applications. This is due to their comparatively higher effectiveness at achieving a higher fossil gas displacement compared to hydrogen production. It is thus vital that the definition of both renewable and low-carbon gases ensures that these gases contribute to emission reductions and have a concrete climate benefit. Bellona has two main recommendations: 1. Clear and precise definitions for Low-carbon gases and Renewable gases are included in the Package, both Diretive and Regulation 2. Remove the 5% cap for blended hydrogen in the natural gas network. Instead of a 5% target for blending, prioritise the use of hydrogen in industries where it’s most necessary and where there are no other alternatives (i.e., direct electrification) The attached document further digs into our reccomandations.
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Response to Guidance on accelerating permitting processes for renewable energy projects and facilitating Power Purchase Agreements

12 Apr 2022

Accelerating the pace at which renewables are deployed is crucial if Europe wants to achieve its climate goals. Renewables are the cornerstone of the energy transition and as they are produced locally, can vastly contribute to an increased energy security, by freeing Europe from dependence on imported fossil fuels. This, however, cannot be done at the expense of the environment. Renewables should be always deployed following thorough and robust environmental assessments, which must be conducted by experts in a swift manner. In order to achieve the goals of the Green Deal, and hitting the targets set out in FitFor55, the roll-out of renewables must speed up from the current 30-35 GW per year to between 45 and 65GW. And if the new ambition set out in the REPowerEU strategy is to be met, a further 80 GW of renewables will need to be deployed over the next eight years. While funding for renewable projects is widely available and the political will to deploy more capacity is clear, permitting has been identified as the key bottleneck for the speed up of the development of this increasingly needed resource. In the current context of high energy prices, under normal circumstances markets would react by redirecting investment in renewables deployment. However, since slow permitting results in increased costs for the developer and high uncertainty, investment in highly needed renewables projects risk being deterred. The Renewable Energy Directive (RED) introduced a provision in 2018 limiting the duration of the permitting procedure to a maximum of two years for new projects and one year for repowered projects. However, evidence shows that Member States are lagging behind in the implementation of this measure. According to WindEurope, the permitting lead time for onshore wind deployment can take up to 10 years. With such long permitting lead times, projects often become outdated before getting built, while changing the technology would result in having to apply for a new permit, creating a vicious circle. Moreover, changing a project (e.g. increasing turbine height) increases the chances of opposition and resentment amongst the local population. Three main points have been identified as the reasons for delayed permitting: complexity of the regulations, understaffing of the relevant authorities, and unnecessary bureaucratic burdens (more detailed in the attached document). Bellona’s suggestions to speed up permitting 1. Increase the power of EU authorities to enforce the existing duration limit for permitting 2. Digitalise and streamline permitting procedures 3. Increase staffing of the relevant authorities, making use of available EU funding, or consider outsourcing parts of the process 4. Establish single contact points to avoid multiplication of bureaucratic procedures 5. Harmonise regulations across regions 6. Identify good permitting practices and disseminate them across Member States 7. Emphasise local benefits to decrease NIMBY movements
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Meeting with Jens Geier (Member of the European Parliament, Rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

6 Apr 2022 · Exchange on the gas market directive

Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

11 Jan 2022

Despite the zero-rating of biomass in the Monitoring and Reporting Regulation, the combustion of biomass emits carbon into the atmosphere. Bellona believes this zero-rating to be a significant barrier to the deployment of actual zero-emission solutions and to the abatement of biogenic carbon emissions which, despite contributing to increased atmospheric CO2 concentrations, are arbitrarily deemed to have no climate impact. Labelling biomass as zero-emission at the point of combustion encourages a demand shift which cannot be sustained, while ignoring the fact that the supply of biomass must be sustainable in the first place. The work of the EASAC and the JRC highlight the existence of a carbon payback period and the difficulty of providing biomass which is beneficial for both climate and biodiversity. As a result of the zero-rating, facilities which emit biogenic carbon have no incentive to stop emitting or to capture and store that biogenic carbon (doing so could potentially result in carbon dioxide removal). This is a missed opportunity to penalise the accumulation of carbon into the atmosphere while encouraging the deployment of technologies which stop or reverse this accumulation, such as a renewable energy or Bio-CCS respectively.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Bellona Europa hereby submit its consultation response, strongly supporting the European Commission efforts to establishing a CBAM. Our two main recommendations provided below, full details and supporting documentation in attachment. 1. Quicker Phase-out of Free Allocation of EU ETS Allowances is Necessary for Ensuring the Timely Success and Effect of the CBAM 2. Indirect and embedded emissions, as well as financial measures to compensate for indirect emission costs incurred from GHG emissions costs passed on in electricity prices, must be included in the CBAM from the start
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Response to Revision of the Energy Tax Directive

18 Nov 2021

Bellona Europa welcomes the proposed revision of the Energy Tax Directive primarily because of the weight of environmental factors in defining the level of taxation has increased. Moreover, the strive to foster the use of renewable electricity across the directive is a very positive development. Likewise, some important steps forward such as the end of tax exemptions for fossil fuels for waterborne navigation and aviation (excluding cargo-only flights) are very welcomed by Bellona Europa. Nevertheless, the push for alternative fuels as part of the overall objective of the proposal, given the current uncertainty around the RED II delegated act for electricity use for RFNBO production, is something whose impacts are hard to assess. Finally, some shortcomings remain in the draft. Most importantly, the exclusion of cargo-only flights, the adoption of weak biomass sustainability criteria from RED II and the persisting tax exemption for unabated fossil gas used in combined heat and power plants are missed opportunities and Bellona Europa believes that these issues should be mitigated in the upcoming legislative negotiations. Below we delve into details on the ability of this directive to address some of the key issues. In the attached document we provide additional feedback on the ability of this proposed legislative file to tackle issues related to RFNBO production, unabated fossil fuels, biomass and climate infrastructure fundings, as well as some key recommendations.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

Bellona considers that the Refuel EU strategy fails to ensure that the aviation sector pull its weight when it comes to climate action. In fact, the proposed solutions for the sector to decarbonise are likely to increase emissions since there are no safeguards in place to prevent perverse outcomes. Paired with the absence of safeguards, we consider the targets proposed for synthetic fuels and biofuels to be deeply flawed. It is likely that these targets will both divert significant resources from other mitigation efforts and increase emissions associated with the process of producing these fuels. For e-fuels, the target is too high since their production is subject to inappropriately weak sustainability criteria established in the RED. Moreover, the high biofuels target will contribute to increasingly unsustainable biomass extraction, likely conflicting with other EU objectives. Providing state subsidies for the production of these fuels would be counter-productive. Finally, there is no guarantee that carbon-based fuels will actually help mitigate climate change since no preference is given to biogenic or atmospheric CO2. Without this, fossil CO2 will inherently be prioritised, which would badly affect the decarbonisation of point-sources and of the aviation sector simultaneously. To avoid detrimental effects from the adoption of this strategy, Bellona proposes to adopt the following key recommendations: First, the production of RNFBOs from industrial CO2 sources must not result in double-counting, where the CO2 emission mitigation would be credited to both the producer of the CO2 feedstock and the user of the fuel. Therefore, we strongly support the Commission’s ETS proposal which specifies that CO2 used can only be considered as stored (i.e. not-emitted) if the carbon is “permanently chemically bound in a product so that they do not enter the atmosphere under normal use”. This will prevent double-counting by requiring the CO2 producer to surrender a carbon allowance under the EU ETS, which would allow the aviation sector to claim the full climate reduction from the fuel. In the longer term, it is critical to ensure that any CO2 used for RNFBO production be atmospheric in origin, to ensure climate neutrality. Second, it is of vital important to include clauses on the source of the carbon to determine if a fuel production process has the potential to be carbon neutral or if it simply results in a slightly delayed emission. In short, we must ask: where is the CO2 from, and where does it go? Capturing CO2 from the atmosphere and using it to produce a synthetic fuel has the potential to be carbon neutral – the same amount of CO2 captured from the atmosphere will be released back to the atmosphere when the fuel is combusted. The atmospheric concentration of climate change causing carbon dioxide will be unchanged. Emissions associated with the production process must also be considered for the fuel to be considered carbon neutral. Capturing geologically-derived CO2, such as from a Cement plant, and using it to produce a synthetic fuel has the ability to reduce emissions but can never be carbon neutral. Ultimately, the Fossil/Geological CO2 is released into the atmosphere, contributing to an increased atmospheric concentration of CO2. Third, the use of 'waste' CO2 cannot be inherently considered as carbon neutral. Both waste emissions from industrial process and emissions from waste must be distinguished by their fossil and biogenic fractions: only the biogenic fraction may be considered carbon neutral. Finally, as e-fuels are a combination of carbon and hydrogen, it’s crucial to ensure that hydrogen production is truly low-carbon, respecting the 3gCO2/gH2 threshold set by the Taxonomy. This requires additional renewable generation to cover the electricity required for green hydrogen production, as well as high capture rate and minimal methane leakage for blue hydrogen. Report on net-zero accounting in pdf
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Response to Restoring sustainable carbon cycles

7 Oct 2021

Bellona welcomes the Commission’s efforts to kick-start the development of technological and nature-based removals. However, clarity must be ensured with regards to what is – and what is not – a carbon removal to prevent wilful and accidental conflation with emission reductions. There is substantial risk that conflating 1. use, 2. storage and 3. removal of carbon will result in confusion and engender the false idea that these very different types of carbon management can be considered interchangeable, an outcome which would damage the credibility of EU climate action and result in significant mitigation deterrence. Therefore, the initiative should provide the necessary clarity and distinguish between different types of activities, namely between an emission, a non-emission, and a permanent removal carbon from the atmosphere. A simple initial assessment can be done by focusing on the source and fate of the carbon in each activity, which provides an overview of the carbon flow: On the source of the carbon, the binary distinction must determine whether the carbon is of atmospheric origin or fossil/geologic origin. So-called ‘waste carbon’ flows must also be characterised by their origin be that atmospheric or geological, as above. On the fate of carbon, a binary distinction must be made between an emission of carbon to the atmosphere or permanent storage (i.e., non-emission to the atmosphere). When CO2 is used in a product (CCU), the outcome may be characterised as a permanent carbon store only in cases where the CO2 is demonstrably stored in a manner intend to be permanent. In all other cases CO2 use (CCU) will ultimately result in the CO2 being emitted and thus its fate must be assessed as an emission of carbon to the atmosphere. These two variables can be used to clearly identify whether a process or project has the potential to result in: Partial emission reduction of 50%. Fossil/geological carbon combined with carbon use and subsequent emission (CCU). Deep emission reduction or non-emission Fossil/geological carbon capture and geological storage (CCS). Atmospheric carbon combined with carbon use and subsequent emission (DAC + CCU) Carbon removal from the atmosphere (CDR) Atmospheric carbon capture combined with geological storage (DAC + CCS; Bio-CCS). Atmospheric carbon capture combined with durable and permanent mineralisation (Bio + permanent storage CCU) It must be noted that for carbon removal, the origin must be atmospheric and the fate must be permanent storage. In addition to the above, the GHG emissions associated which each of the processes will need to be comprehensively estimated and included in the overall emission balance. This full lifecycle assessment should include all the steps (such as indirect land-use change, emissions from energy use and transport) involved in the activity. The permanence of storage and the risk of reversal must be assessed and accompanied by an appropriate framework for MRV and liabilities. With the above recommendations, this initiative is a vital opportunity to operationalise ‘net-zero accounting’ whereby the climate value of a different CO2-based activities is defined by its individual real-life and absolute effect on the CO2 concentration in the atmosphere (i.e. the amount of CO2 removed and/or the amount of CO2 added to the atmosphere). While the Sustainable Carbon Cycles roadmap may benefit from using CDR as a baseline to compare other types of climate action, efforts to promote carbon removal and emission reductions must be kept separate, in line with the European Climate Law. Attached you will find a short report entitled 'Net-Zero Compatibility Test' which help to visualise the above points and illustrates the importance of the source and fate of carbon.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

For the full version of Bellona Europa's Response to Public consultation on EU Sustainable Finance Taxonomy Article 8 Delegated Act see attachment, also including letter sent to commission 16th of March Bellona Europa commends the important steps taken by The European Commission by the publication of this proposed Delegated Act. It is a continuation of the Commission’s dedication to provide clarity and transparency on upcoming reporting requirements – addressing concerns and allowing for feedback for those involved and subjected to the regulation. As a result of the published proposal for a Delegated Act for Article 8, the picture of what will be needed to report on, how and timeline, has become clearer. Bellona Europa have analysed the proposal, and would like to bring to your attention our concerns and recommendations. - Annex I “KPIs of non-financial undertaking” currently allow for CapEx investments part of 5-7 year plans to make activities taxonomy-aligned, reported as sustainable under the taxonomy. This is particularly relevant to points 1.1.2.2 and 1.1.3.2 of Annex I, but is referenced throughout the text. Without the necessary safeguards, plans for future alignment being reported as sustainable under the taxonomy will reinject subjectivity – and work against the much-needed objective scientific sustainability classification tool that the green transition depends on. Narrative reporting on future potential alignment with Taxonomy plays an important role in communicating transition plans to investors to attract capital, but should not be reported as sustainable under the Taxonomy before the necessary performance in line with technical screening criteria is met. We do not see the required reporting on such 5-7 year plans as sustainable under the Taxonomy being safeguarded sufficiently in the current proposal. Our concern with the proposal published is the lack of any enforceability or retroactive checks included – and we worry that lofty plans attracting sustainable finance with no consequences would create perverse incentives and jeopardize the Taxonomy’s credibility. We therefore recommend that until enforceability, consequences for misreporting and retroactive checks are included in the proposal, plans for future alignment under the Taxonomy should not be counted as sustainable under the taxonomy today. - We would like to commend in particular the work of the Commission in Annex II – setting out clear templates exemplifying the format of the report. This brings much-needed clarity for those subjected to reporting requirements. It is however not clear from the table what is included in the numerator in columns 18 and 19 – setting out “Taxonomy aligned activities”. If it includes, which is our understanding, sustainable, enabling and transitional activities, this must be specified and a separate column for the specific reporting of sustainable economic activities must include as well – as is the case for both enabling and transitional activities in columns 20 and 21. If enabling and transitional activities are not included in the numerator of column 18 and 19, this should be specified for clarity. We do believe it is important to report on enabling and transitional activities separately, but these reports can only play its intended function if it can be compared not only to the aggregated alignment with taxonomy, but also the sustainable activity alignment under the taxonomy. We therefore recommend that clarity is ensured for columns 18 and 19 and to what extent they are aggregate, and that the alignment of sustainable economic activities are also reported on in a separate column as is the case for enabling and transitional activities. - We also recommend that Article 10 is amended to reduce the barriers for including additional aspects of the delegated act into the planned review in 2025, expanding the scope of this planned review
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Response to Union Renewable Development Platform (URDP)

27 May 2021

Statistical transfers, as they are laid out in the Renewable Energy Directive, constitute an obstacle for the deployment of renewable energy where they are most needed. Allowing uncapped “transfers of statistical value, without requiring a physical transfer” amongst Member States to comply with the targets set by the Renewable Energy Directive entails a number of issues. Additional renewable electricity generation does not displace the same amount of emissions in all member states. The higher the carbon intensity of the production displaced through additional renewable generation, the higher the displaced emissions. For example, wind power generation will reduce emissions more effectively in areas where the grid is powered mostly by fossil fuels. Therefore, allowing a statistical transfer from a country where the power generation is low carbon (for instance France) to a country where the grid has a high carbon intensity (for instance Poland) drastically reduces the climate change mitigation of the renewable energy generation. In other words, statistical transfers allow for fossil fuel use for electricity generation in areas where renewable energy deployment is most needed. Statistical transfers do not provide an incentive for additional renewable energy generation. They deviate investments from supporting renewable generation deployment to accounting tweaking. All the funds invested into this mechanism should be invested in deploying renewables instead and thus actually contribute to the energy transition. Since transfers are just statistical, they do not need to reflect any real ability of the grids to transfer electricity from one area to another. Therefore, potentially excess electricity generation which needs to be curtailed in one Member State can be accounted as contributing to the Renewable Energy target of another Member State, despite the fact that this cannot be physically transferred because of poor grid interconnectivity. The Commission is currently revising the Renewable Energy Directive in order to strengthen its targets to align it with the newly adopted climate law. This delegated act should therefore be in line with the more stringent requirements and increased targets that will be set in the RED. In particular, the Commission should consider capping statistical transfers to the amount of electricity that can actually be transferred from the selling Member States to the buying Member States. The longer these statistical transfers are left in the system, the harder it will be to reach binding climate goals in 2050. While some flexibility might still be necessary, reducing and capping statistical transfers and connecting them to physical renewable energy flows and deployment would help build a climate-proof electricity system in the EU. With the right incentives and changes to instruments such as statistical transfers, the EU could strengthen the grid, improve interconnectivity and bring more renewable deployment to member states that need it the most.
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Response to New EU urban mobility framework

25 May 2021

Bellona welcomes the European Commission initiative for a new urban mobility framework, with sustainability at its core. Transport has high negative environmental externalities in cities, being responsible for a large share of urban greenhouse gas, NOx and PM emissions, as well as noise pollution and congestion. Drastic action is thus needed to shift urban mobility to more sustainable means and patterns. This requires addressing transport in a holistic way, focusing on electrification, change of modalities as well transport of goods and non-road mobile machinery. A switch to electromobility and active mobility can address the emissions of greenhouse gases and pollutants and reduce noise, while improving overall wellbeing. The new urban mobility framework should aim at enhancing the measures to electrify the transport sector adopted through the AFID, TEN-T and EPBD, to achieve faster results in cities, where they are most needed. One of the main hindrances to the uptake of private EVs is the lack of easily accessible chargers. Therefore, increasing the availability of public charging, can contribute significantly to this drivetrain shift. This can be achieved by setting more ambitious targets in the urban context, where people tend to have more limited access to private parking equipped with chargers. A particular focus on multi-modality should be placed in cities, to allow for the progressive shift of urban mobility from private vehicles to public and active transport. Acting on the integration of several transport means, making them attractive and easily accessible stimulates the urban population to use more sustainable transport means. This can limit the use of private cars only where they are the only available option, making the overall transport system more efficient and decreasing its environmental impact. Zero-emission zones are a powerful tool to increase the use of electric or alternative means of transport in cities. This instrument can also be used to incentivise the uptake of electric solutions beyond transport. To ensure the wellbeing of city dwellers these zonal regulations should include other sectors which are big emitters, namely non-road mobile machinery from the construction sites. These are responsible for large share of cities GHG emissions (7% of the total GHG emissions in Oslo), as well as local air pollution and noise. Addressing the emissions from construction sites can help cities to decarbonise, as well as improve the wellbeing of workers on the construction sites and residents of the area. Beyond shifting drivetrains, real emission reductions can be achieved through the streamlining of logistics activities by reducing the number of vans delivering goods in urban areas. Bellona has performed a study on the optimisation of transportation to and from construction sites. This case study in Oslo observed that streamlining transport of goods in the construction industry can reduce emissions by 50% while increasing productivity. By limiting the time at which delivery to the construction site was allowed, vans delivering materials to construction sites were filled to a greater extent, thus halving the number of trips. To streamline logistics regulators can act on requiring a standardised reporting of transport of goods, setting requirements for fixed times for deliveries, and making reduced transport a priority in the aim to reduce emissions and congestion. Overall, Bellona encourages the Commission to include in the new urban mobility framework the following aspects: 1. Higher targets for the installation of public chargers in cities, as urban dwellers have less access to private charging. 2. A focus on multi-modality to incentivize public and active transport. 3. Zero Emission Zones, expanding their requirements as to ensure the inclusion of non-road mobile machinery from construction sites. 4. The adoption of legislations to streamline logistics, to increase the efficiency of goods delivery.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Bellona welcomes the decision of the Commission to revise the EPBD in light of the new targets for 2030, aiming at doubling the building renovation rate by 2030. Buildings are responsible for over a third of the energy-related GHG emissions in the EU, thus the revision of the EPBD is necessary to reduce emissions by 55% by 2030. In particular, we welcome the acknowledgement that the EPBD should explore the synergies with the Smart and Sustainable Mobility Strategy. Today, transport is responsible for 30% of the CO2 emissions in the EU. The EPBD can foster deep decarbonisation in road transport by facilitating the transition to electric mobility. To achieve a fully electrified car sector by 2050, ICEs should not be sold after 2035. This means that buildings need to be EV ready as soon as possible. One of the main hindrances to the uptake of private EVs is the lack of easily accessible chargers. Although fast-chargers cover part of the charging demand, EVs are most charged when parked at home or at the office. Therefore, equipping buildings with chargers is key to support this transition. This can be fostered through the EPBD by incorporating the following requirements. The current EPBD exempts SMEs from applying electro-mobility provisions. However, SMEs are 99.8% of all enterprises in the EU. Applying exemptions only to small and micro-sized enterprises would increase the reach of the directive from the current 45000 enterprises to approximately 265000. Equipping office buildings with charge points leads to a 20-fold increase in the likelihood of EV purchase among employees, thus we consider this action of utmost importance. The extensive installation of pre-tubing is a cost-effective and future-proof measure, as it reduces the costs of installing charge points at a later stage by roughly 75%. Therefore, pre-tubing should be considered the standard in all new and substantially renovated buildings, not only in those with more than 10 parking spaces, as foreseen by the current directive. The EPBD should also look beyond pre-tubing. Space for additional electric meters and control units for smart charging should be included in the requirement to make buildings future-proof. Moreover, studies show that renters are roughly 3 times less likely to buy an EV than home-owners, even when income levels are the same. To mitigate this discrepancy, the installation of charge points in public parking lots and areas concentrating multi-tenant apartment buildings should be prioritised, over just pre-tubing. Today, long and uncertain approval procedures act as a major barrier to install charge points in existing multi-tenant buildings. This de facto hampers the installation of charging infrastructure and switching to EVs. The enactment of the “right to the plug” building codes would guarantee that parking space owners in residential and non-residential buildings are seamlessly able to install, at their own expense, an EV charge point without any further approval or procedure, other than the prior communication to the building co-owners. Moreover, given the increasing penetration of renewables on the European grid, EVs and chargers can play a role in load balancing and storage. To achieve this, buildings should be equipped with smart chargers, able to charge when renewables are widely available and serve as backup power in low production moments. Charger interoperability is essential and smart power distribution systems in multi-tenant buildings are key enablers for smart charging. Finally, we welcome the acknowledgement that emissions linked to a building go beyond their operation and are also linked to the “production and transport of materials, construction, refurbishment and end of life”. To achieve a substantial emissions reduction in these phases of a building life, we encourage the Commission to mandate the use of zero-emission construction site machinery and equipment for the construction and renovation of buildings.
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Response to Revision of the guidelines for trans-European Energy infrastructure

22 Feb 2021

Bellona Europa provided an earlier version of its feedback on the 22/02/2021. We ask that you disregard that version and rather see the updated one below. The TEN-E Regulation has since its creation in 2013 contributed greatly to its set objectives and aims. A much-needed revision is now underway to ensure alignment of these aims with the European Green Deal, shifting the TEN-E's focus from security of supply to security of sustainable supply in line with the Union’s decarbonization targets. Although the current proposal for a revised TEN-E regulation improves the legal text across several of the included categories, no changes have been made to the Priority Thematic Area (12) “Cross-border carbon dioxide (CO2) network”. Bellona Europa has supported the ongoing revision process from the start, including participation to the targeted evaluation study through interview, highlighting in particular the need to include CO2 storage and transport modalities other than pipelines. Despite our efforts, the current proposal from the European Commission does not include these two important aspects, we therefore find it necessary to again highlight our recommendations in this consultation reply to the TEN-E Regulation. Additionally, while the draft proposal longer includes a dedicated natural gas category, it has seemingly merely been replaced by the category “smart gas grids” with references to various forms of “renewable and low-carbon gases”. The inclusion of ill-defined low carbon and renewable gases in the draft TEN-E Regulation, would still allow fossil gas projects and development of new fossil infrastructure to be eligible for Project of Common Interest (PCI) status. For Bellona Europa's full response please see attached document. We are looking forward to an opportunity to discussing our suggested edits with you in greater detail
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Response to Revision of EU Ambient Air Quality legislation

14 Jan 2021

Bellona sincerely welcomes the taking into account of the points expressed in the previous contribution, including the recognition that current air quality standards were largely missing the WHO recommendations. However, it’s important to aim at a full alignment with WHO recommendation, rather than just a closer alignment. Moreover, the WHO states that there is no ‘safe limit’ of air pollutants, thus targets should be set in a progressively stringent manner, as to eventually drive pollutants level to zero. Bellona also welcomes the aim to increase the scope of the AAQD to include other pollutants not previously considered, such as ultrafine particles. Moreover, clearer coherence between the Ambient Air Quality Directive and relevant emissions legislation should be envisaged. Specific legislation to limit the emissions from sources should be aligned with the aim to limit ambient pollution levels to within WHO Guidelines. As of today, penalties have not been strict enough to oblige countries to meet the objectives. Stricter and more effective enforcement mechanisms that would ensure the compliance to national and local targets, thus protecting the health of the citizens, must be implemented. A simple merging of existing directives and a simplification of procedures will not be sufficient to reach the aims of the AAQD. No less, Bellona encourages the continued legal procedures against Member States failing to respect the thresholds set in the Directive. Clear enforcement mechanisms need to be established at the Union level, in order to ensure consistent addressing of air quality issues across the continent. This may include automatic vehicle bans in case of high pollution. Complementarily, policies on the reduction of available parking space and increase of tariffs; incentives to dispose of old vehicles and/or to purchase zero-emission ones; as well as ULEZs and congestion charges to enter dense urban areas should be encouraged to tackle pollutants emission in a more holistic way. Furthermore, indirect emissions represent an additional problem to public health and should thus be tackled. This includes particulates deriving from brakes, friction, road and wheel tear, and resuspension of road particulate matter. Specific legislation to foster the adoption of technological solutions limiting these emissions is therefore needed. Previous EU legislation has had the unintended effect of increasing the size of vehicles, this must be addressed. The work undergoing to internalise the external costs of transport should be applied as soon as possible. Previous Bellona research suggests that if the human health impact of air pollution from transport were included, the purchase price of the average ICE would double. The importance of citizen science in monitoring air quality cannot be understated. The EU should strive to provide financial and logistical support to promote these activities. Finally, very localised and intense bursts of pollution, from machinery for instance, cannot be measured with hourly or daily averages, hampering the effect of this legislation on them. Such pollution represents a health risk for workers in close contact with the machinery. This issue could be solved by introducing specific requirements for both measurement and abatement of these emissions in construction sites and similar settings beyond the outdated targets set by the NRMM Regulation. See Bellona’s previous contribution here: https://bellona.org/news/fossil-fuels/2018-07-bellona-response-to-ec-consultation-on-the-fitness-check-of-the-ambient-air-quality-directives See Bellona’s research on the external cost of ICE vehicles here: https://bellona.org/publication/bellonabrief-rethinking-the-cost-of-conventionally-fueled-road-transport
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The European Commission’s continued dedication to a timely finalisation of the Sustainable Finance Taxonomy Delegated Acts (DAs) on climate change mitigation and adaptation is commendable. We are happy to see that the published DAs stay close to the Technical Expert Group’s (TEG) recommendations presented in March of this year. This is in line with the recommendations presented by Bellona Europa in April of this year. The final DAs will define the future role and uptake of the Taxonomy, and above all its ability to direct capital to sustainable investment projects. Through our analysis of the DAs published on the 20th of November we have identified several steps and recommendations to ensure the climate impact credibility of the Taxonomy, and support its long-term relevance and uptake. The full basis of our recommendations can be found in the attachment, along with supporting information and sources. 1. Keep the set value of the substantial contribution to climate change mitigation criterion for electricity at 100g CO2e/kWh 2. Reinstate the declining nature of the 100g CO2e/kWh life cycle emission threshold 3. Reinstate full life-cycle climate change mitigation DNSH criteria and set a clear reference and declining trajectory for review in line with technological and market developments 4. Remove exemption allowing projects with a lifespan below 10 years to be assessed against “downscaled climate projections” 5. Ensure ambitious threshold in line with long-term technological and market developments 6. Ensure that point 4.14 of both DAs on “Transmission and distribution networks for renewable and low-carbon gases” does not enable construction of fossil gas infrastructure 7. Ensure proper and harmonised emissions accounting methodology of Hydrogen under point 3.9, ensuring transparency and comparability 8. Urge EU leadership to ensure a science-based definition of Carbon Dioxide Removal (CDR) to be included in the future Taxonomy. 9. Exclude Carbon Capture and Utilisation (CCU) without guaranteed permanent storage You can find Bellona Europa's full consultation feedback with additional sources and supporting information in the attached document. We are looking forward to an opportunity to discuss these recommendations further, should there be questions or necessary clarifications.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Bellona Europa Response to the Inception Impact Assessment for the “Revision of the Guidelines on State aid for environmental protection and energy 2014 – 2020 (2014/C 200/01)” Bellona Europa welcomes the ongoing revision of the EEAG and the priorities outlined in the Inception Impact Assessment. A detailed technical feedback will be submitted through the targeted public consultation by the set deadline 7th of January 2021. Additional information, examples and supporting documentation can be found in the attached feedback to DG Competition submitted on the 20th of November. While the planned impact assessment contains many of the important aspects vital to the ongoing revision, we present the below overarching recommendations to guide the ongoing revision process. Safeguard Climate Impact Credibility of EEAG and GBER As acknowledged by the European Commission, it is clear that the current text of the EEAG does not reflect the important progress and market developments taking place since 2014. Additionally, with the launch of the European Green Deal, the European Commission has clearly set climate change mitigation and the green transition at the very top of its agenda. This warrants a much needed update of the EEAG. It is in this context of the utmost importance that we ensure that state aid does not finance or incentivise economic activity that counteract these policy priorities. The revision of EEAG and GBER must ensure that the interpretation of the “common interest” principle relied upon in the EEAG reflect the increased importance and weight of environmental benefits as outlined through the European Green Deal. Bellona Europa has already addressed this point in detail through our previous feedback. In addition to increase the weight of environmental benefits in the “common interest” principle, the revision of EEAG and GBER must safeguard its climate impact credibility by ensuring that no state aid funding is awarded to economic activities with a detrimental effect to the climate or EU’s climate neutrality target by 2050. Therefore, no state aid funding should be awarded to economic activity in breach of the Do-No-Significant-Harm (DNSH) principle as outlined in the Sustainable Finance Taxonomy. The EEAG is not functioning as intended when it comes to section 3.9 “Aid for Generation adequacy”, and is in fact contributing to a continuation of and in some cases incentivising fossil fuels over renewable alternatives. It is therefore vital that the ongoing revision revisits the design of provisions for capacity mechanisms under the EEAG to ensure alignment with the DNSH criteria. This has been outlined in detail, with examples and supporting documentation in our earlier feedback. NGOs are currently facing disproportionate barriers, as well as outright exclusion, from being able to contest decisions on state aid. As outlined in our previous feedback, this exclusion shows a democratic deficit, made worse by the fact that industry has and is able to access the courts to challenge decisions on commercial grounds. The ongoing review must ensure that NGOs and civil society has the necessary access and rights to conduct its important societal role, holding decision-makers, private sector and society as a whole accountable to the commitments under the European Green Deal. We have also observed a need to provide further clarity and incentivise information sharing when it comes to projects and economic activities eligible for state aid. This is highlighted in our previous feedback, along with concrete examples, and our recommendation that a clear, easily accessible dynamic information channel should be set up to fill the existing information gap. We trust these recommendations will be taken into due consideration in the ongoing process, and are happy to provide additional information and documentation should this be of interest.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Please see attached for Bellona Europa's input to the Roadmap
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Response to Sustainable Products Initiative

16 Nov 2020

We welcome the Sustainable Product Policy Initiative’s intention to assess the true environmental impact of products and correct existing market failures which do not take into account their externalities. The current EU policy framework needs to be amended to reflect the true cost of all products. Therefore, we welcome a stronger regulation and the introduction of incentives for sustainability-related aspects into a wide range of product related instruments. As outlined in the Inception Impact Assessment, we concur that products should be designed to be durable, repairable and finally, recyclable before they reach disposal. Furthermore, many externalities related to manufactured goods, such as climate impacts, are significant. As such, they should be taken into account, particularly for large industries such as steel, cement and chemicals. In addition to informing consumers, internalising climate impacts would allow these industries to create new markets and pursue more ambitious climate action strategies. General recommendations Establish clear metrics in the EU policy framework on sustainable products on parameters such as climate impact: o Establish a methodology for the transparent accounting of emissions across the entire lifecycle of the product (i.e. resulting calculation could show x tCO2/t product). Make links to relevant policies and synchronise efforts on sustainable products with targeted, sectoral action. o The outlined sustainability criteria need to be mentioned in sectoral plans to ensure policy coherence. For instance, for products such as cement, steel and chemicals, Sustainable Product initiatives should be coordinated with the new Industrial Strategy1 for Europe and all similar efforts to ensure policy coherence. Reducing the environmental impacts of products means that resources extracted have to be used as efficiently as possible. Consequently, measures to reduce environmental impacts of products should prioritise long lifecycles and value retention. The monitoring and verification of information provided for the various products will be necessary to ensure their sustainability. o For instance, such market surveillance can be supplemented and coordinated with existing databases which record the impact of the production of products such as steel, cement and chemicals at its source (e.g. Monitoring and Verification system of the EU ETS). More recommendations on the SPI for steel, cement and chemicals are available in the attached document.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Please find attached Bellona Europa's full response and recommendations to the Roadmap Consultation "EU renewable energy rules - review" as well as our recommendations for the REDII delegated acts for your reference. We are happy to contribute further to the process and offer our expertise on the topic should this be of interest to you continued work. Here is a short summary of Bellona Europa's recommendations: 1. The renewable energy target should be increased to reflect the increased emission reduction target by 2030. The overall renewable energy target should also be increased to reflect additional renewable electricity demand from direct electrification and hydrogen production for sectors such as transport and industry. 2. A revision should not jeopardize the important steps in the right direction taken by the RED II. We therefore encourage caution as it pertains to option 4 - “Amend REDII to translate into legal measure the actions proposed in other energy strategies of the EGD” outlined in the Roadmap document. 3. Maintaining the climate integrity of the REDII and defining sustainability criteria for low-carbon fuels is crucial for the Directive to lead to significant emission reductions. 4. Exclude fossil Recycled Carbon Fuels from the REDII 5. Ensure robust and correct accounting of all emissions related to Renewable Fuels of Non-Biological Origin
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

24 Jul 2020

Bellona Europa endorses the improvement of existing Rules on Monitoring, Reporting and Verification of the EU ETS MRV by making them both more efficient and more up to date exercise and strongly believes that correct and transparent accounting, enabled by accurate monitoring and verification of emissions will be the make or break of the carbon neutral economy. The EU ETS’s cap is directly connected to the net zero EU we all strive for under the EU Green Deal and, in that sense, it works as the trajectory ensuring progressive ratcheting of the scheme towards carbon neutrality as well as scarcity on the market of tradeable allowances. However, the cap requires extremely clear accounting of all emissions released from the installations covered by the EU ETS. For this to be achieved uniformly across the EU, the proper monitoring, reporting and verification are key elements and it is for this reason that a Regulation is the necessary legal tool – to ensure that interpretation of all emissions accounting is uniform all across the carbon market. The MRV Regulation is, in that sense, the enabler of the EU ETS and it is of utmost importance that the integrity of the accounting is kept as safe from unproved and therefore questionable methodological approaches. We are concerned that in the process of revising it, certain unproved yet calculation methodologies with regards to “avoided emissions” could be let inside the scheme, which could jeopardise the integrity of the ETS. On this basis, Bellona Europa recommends five principles which will ensure that accounting under the MRV Regulation is “robust, transparent, consistent and accurate” as the Commission sets its purpose to be: 1. Any methodology which allows for emissions created in ETS installations to exit the ETS without being accounted for should be prevented. Installations must be fully accountable for emissions generated under the EU ETS. 2. Novel emission accounting principles, such as the accounting of emissions which are ‘avoided’ elsewhere, cannot be included into the MRV Regulation without a transparent and thorough impact assessment. Avoided emissions should not be used to change the physical metrics within the MRV Regulation (i.e. emission factors). 3. Technologies that claim permanent storage of carbon have to match the principles and safeguards in the definition of permanent storage of CO2 already available under the EU ETS (Article 49 of the MRV Regulation and Directive 2009/31/EC): o Emissions must be monitored in order to ensure leakage has not occurred o Emissions must be verifiably permanently stored 4. Setting the foundations and methodology for assessing circular economy climate impacts requires measurement of total emissions to the atmosphere from the production, reuse and recycling of products. In an increasingly complex system of solutions and overlapping strategies, it is imperative that any loopholes in accounting are avoided. 5. Parallel legislative processes aiming to define the accounting for the same technologies could result in duplicated awards of emissions reductions and overlapping loopholes. In order to avoid such issues, any additional changes to the MRV Regulation should be assessed systemically, in coherence with other policies (such as the REDII). For more information on the recommendation and underlying analysis, please see attached file.
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Response to Modernising the EU’s batteries legislation

7 Jul 2020

Bellona Response to the Batteries Roadmap Bellona welcomes the batteries roadmap as a way to improve the sustainability of batteries while still ensuring the competitiveness of the sector. Electrification is the best way to eliminate emissions from road transport; will play a role in the decarbonisation of ships and machinery; and is already contributing to addressing the challenge of energy storage; which means that batteries will become the backbone of the economy’s decarbonisation. The post-COVID recovery of the economy, and the future Battery Regulation should focus on the sustainability of the entire battery value chain without jeopardising the competitiveness of the EU market or hindering electrification from decarbonising polluting sectors. The Battery Strategy must keep in mind that batteries already have better environmental credentials than fossil fuels, so any sustainability requirements should not slow down the phase-out of fossil fuels. Lifecycle CO2 emissions of battery electric vehicles are already 2-3 times lower than combustion cars, the difference increasing as the electricity mix gets cleaner. It is also important to note that the carbon footprint of batteries is reducing and will get even better with the technologies succeeding li-ion. Batteries charged with electricity are already and will always be the more sustainable alternative when compared to fossil derived energy carriers, their advantage further increasing when also taking into account the emissions of NOx and PM2.5 from exhaust fumes, as well as PM10 from the much more frequent use of mechanical brakes in ICE vehicles as opposed to regenerative braking in EVs. The updated IVL (Swedish Environmental Research Institute) study in 2019 reported a 2 to 3-fold reduction in battery carbon footprint (61-106 kgCO2/kWh range) compared to the 2017 range of 150-200kgCO2/kWh. Some battery manufacturers such as Saft or Northvolt are already reporting a much lower carbon intensity of their batteries. Still, Commission efforts should be targeted towards reducing GHG emissions from battery manufacturing where possible, especially by favouring renewable energy sources for battery cell production. In order to improve batteries’ traceability, a single identification system (i.e. through a Battery Passport) which is managed at EU level, is key for facilitating the sorting & recycling of batteries and thereby making the recycling process more economically sustainable. Battery warranty as well as lines of responsibility between economic actors need to be defined (i.e. extended producer responsibility). This will help with developing business models which incentivise and facilitate re-use and recycling activities for batteries. Especially for second life batteries, an EU wide system for the evaluation of the state of health of a battery needs to be established in order to identify how end-of-life batteries can be re-used in second-life application. Mandatory targets of key recycled battery materials is a topic which needs further assessment, but which is essential in order to achieve a sustainable battery value chain with maximum re-use and recycling rates.
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Response to A EU hydrogen strategy

8 Jun 2020

Low- and zero-carbon fuels (hydrogen, ammonia, methane and other hydrocarbons) will be a valuable and scarce resource in the future due to their high resource requirements. In that context, Bellona welcomes the initiative to define a comprehesive EU hydrogen strategy which should set robust environmental and climate criteria for the large-scale deployment of hydrogen. In the case of synthetic liquid and gaseous fuels such as hydrogen, the energy-intensive production process and the electricity resources used for it will determine their climate impact. Since hydrogen will require significant resources to produce, the environmental criteria for its production should be determined prior to their large-scale deployment. Regardless of how the low carbon hydrogen is produced, a full lifecycle assessment must take into account all indirect emissions caused by or associated to its production. Hydrogen production For any hydrogen production process, it is important to consider the entire production process and all inputs to evaluate the climate impact of the H2. Setting thresholds and climate criteria for hydrogen production will be crucial to stimulate the development of truly low-carbon fuels. When produced in accordance with robust environmental standards, different hydrogen sources can aid co-developing transport infrastructure, supplying the same market and growing the share of hydrogen as a clean energy source. Recommendations: When calculating the emissions of hydrogen from electrolysis, the following emissions should be taken into account: o the carbon intensity of the electricity used to produce the fuel, in gCO2/kWh of respective national grid (unless directly connected with RES). o Using breakeven points to define truly low-carbon hydrogen could be a way to strengthen current prerequisites for the production of these fuels in the EU Hydrogen Strategy:  less than ~149gCO2/kWh for hydrogen via electrolysis (estimated breakeven point with fossil natural gas)  less than ~90gCO2/kWh for synthetic hydrocarbons (estimated breakeven point with fossil counterparts) o the carbon added (if any) fossil (e.g. from industrial point sources) or atmospheric (e.g. CO2 from direct air capture) + the energy used to capture the carbon o To ensure the compatibility with climate goals declining thresholds for carbon intensity (e.g. 100gCO2eq/kWh to 0gCO2eq/kWh by 2050 from the Sustainable Finance Taxonomy) should be used for financial mechanisms supporting low-carbon fuels. o Predictions of the emission factor of the grid in 2030 and 2050 should not be used to calculate the climate impact of electrolytic hydrogen today. Hydrogen use and infrastructure Recommendations: Precise and targeted use of truly low-carbon gaseous and liquid fuels (meeting criteria above) where direct electrification is not an option or is very difficult: o Dedicated infrastructure for hydrogen use in sectors which do not have direct electrification options, e.g. energy intensive industries (ammonia production, direct iron reduction) Dedicated infrastructure for handling and transport of low-carbon fuels (e.g. hydrogen and ammonia) to avoid blending within the large natural gas grid. o Investment in hydrogen projects meeting the thresholds for low climate impacts in comparison to their fossil counterparts (e.g. in a region with electricity emission factor of 50gCO2/kWh) For a more detailed analysis, please find the attached file.
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Response to Strategy for smart sector integration

8 Jun 2020

The EU Smart Sector Integration Strategy is a prominent element of the European Energy Transition, which is why Bellona supports the Commission's initiative to quantify its impact and ensure its environmental integrity. Efficient use of resources could provide a moderate environmental benefit and potentially some reductions in greenhouse gas emissions. By expanding the electricity grid, improving electricity distribution, developing smart grids and integrating demand response in the power market we can build a more resilient and low-carbon energy system. However, smart sector integration – particularly in sectors such as energy intensive industries - only results in climate change mitigation under certain conditions. It is therefore important to note that in addition to smart sector integration actions, the transformation of energy intensive industries will call for other direct climate change mitigation efforts. Key recommendations: Climate screening criteria for Smart Sector Integration To ensure that smart sector integration actions actually contribute to emission reductions, we recommend the use of the following screening criteria and their respective metrics for the initial climate evaluation of Smart Sector Integration actions: 1. Evaluate efficiency of climate change mitigation per input of energy, in CO2t/kWh It is important to recognise that not all smart sector integration activities will deliver the same result from a climate point of view. Direct uses of electricity which deliver the largest decarbonisation per input of energy should be prioritised where possible. As electricity needs increase, it will be important to prioritise its efficient use to manage the demand. Where possible, direct electrification measures such as heat pumps or vehicles with electric drive trains should be prioritised. 2. Evaluate the use of resources and do not discount ‘waste’ carbon flows to the atmosphere: - Use of electricity or energy resources, in gCO2/kWh of respective national grid (unless directly connected with RES). - Use of liquid or gaseous fuels, scientific emission factor for fuel in tCO2/TJ - Use of waste, mass balance and flows in metric unit for mass kg, t, kt, Mt Tracking the carbon flows through and out of the industrial system into the atmosphere is crucial for the assessment of the climate impact of smart sector integration. For instance, industrial clusters can use resources very efficiently, but still could have a large emission point at the end of life of the production line. The suggested metrics can account for the most significant indirect emissions associated with a particular project, coming from either energy use, electricity use or the use of waste whose end-of-life fate has to be accounted for. 3. Do not include emissions avoided elsewhere in the system into the calculation of greenhouse gas emission reductions. To retain the possibility to monitor reductions and avoid creative accounting, the scale of emissions mitigated by the smart sector integration action should be assessed only directly at the point source. Avoided emissions shouldn’t be accounted for elsewhere in the system - only reductions on site and attributed to a given smart sector integration action should be accounted for. 4. Do not use data which does not reflect real-life and real-time emissions in the system. The GHG criteria in the Innovation fund use zero-carbon electricity from 2050 for projects because they assume that they will be scaled up in the future.This must not be used as a precedent for calculating the impact of projects, as it does not reflect real-life emissions. For a more detailed analysis, please find the attached file.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

Response to the Published Roadmap for Revision of the “Trans-European Energy Infrastructure” (TEN-E) Regulation Bellona Europa strongly supports the EU’s commitment to climate neutrality by 2050, and the need to revise regulation (EU) No 347/2013 “Guidelines for Trans-European Energy Infrastructure” (TEN-E). To ensure compatibility with more ambitious climate action and the vision of a carbon neutral Europe by 2050, the end result of an overhauled TEN-E must therefore encourage and only develop the energy carriers consistent with the transition to a low-carbon world. The highest priority must be given to electricity grid expansion, hydrogen dedicated infrastructure and CO2 infrastructure. This will connect Europe’s different renewables, facilitating their direct and effective use as well as ensuring security of supply and availability. In situations where gaseous fuels may be used, or where electricity is not used directly, only dedicated hydrogen infrastructure should be developed, and industrial clusters should be prioritised in this regard. Bellona Europa therefore recommends that the European Commission ensures the revised TEN-E: 1. Keep Carbon Dioxide Transport as one of the 12 strategic trans-European energy infrastructure priorities It is our strong recommendation that the TEN-E continues to include “cross-border carbon dioxide networks” as a priority thematic area, as outlined in Annex I “Energy infrastructure priority corridors and areas” (12), which states that the regulation applies to the “development of carbon dioxide transport infrastructure between Member States and with neighbouring third countries in view of the deployment of carbon dioxide capture and storage”. The current TEN-E has already aided the advancement of industrial decarbonisation, notably projects taking place in Rotterdam and Ireland, as well as the Northern Lights project. The Port of Rotterdam project is the most advanced EU project for widespread industrial decarbonisation, with CO2 transport and storage playing a key part. With some of the strictest emission reduction targets for industry, the Netherlands have benefited from European aid and support in the development of CO2 transport and storage networks, facilitating a continuation of high ambition levels. The PCIs which include CO2 transport and storage has enabled the clear “business case” of low-carbon industry, and made it clear that decarbonisation can and should happen now. Postponement of action is not an option, and we need to invest today to ensure the solutions of tomorrow. Ways in which the TEN-E could be improved to support industrial decarbonisation: • In Annex II (4) “concerning carbon dioxide”, we recommend that the European Commission removes the exclusion included in point (b), where it is stated that it does not include “infrastructure within a geological formation used for the permanent geological storage of carbon dioxide…and associated surface and injection facilities” • Ensure the inclusion of all CO2 transport modalities – pipeline, ship, barge, train, truck and related docking facilities – in the revised TEN-E. There should also be an accompanying effort to harmonise relevant legislative frameworks, such as the EU ETS 2. Exclude unabated fossil fuel infrastructure as eligible for EU funding under the regulation In order to align TEN-E with the EU Green Deal, we therefore ask the European Commission only to consider funding for projects which meet the criteria outlined in the Sustainable Finance Taxonomy, as outlined by its Technical Expert Group. The EU should not be funding projects contributing to increased levels of carbon dioxide in the atmosphere, and a TEN-E consistent with the climate neutrality objective cannot offer funding to fossil fuels projects, e.g. unabated fossil gas projects. Please see attached PDF for further details, references and supporting information.
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Response to Climate Law

1 May 2020

Bellona Europa Response to the proposal for a regulation “European Climate Law – achieving climate neutrality by 2050” Bellona Europa welcomes the European Commission’s regulatory proposal for the “European Climate Law”, but warns that the current proposal fails to take into due consideration current estimates’ overreliance on the future availability of Negative Emissions Technology and Practices (NETPs) at a large scale. Bellona Europa have issued several warnings on the topic, both in our responses to the Climate Law Roadmap and the 2030 Climate Target Plan. Our warnings were referenced in the recently published European Parliament Briefing “EU Legislation in Progress” on the European Climate Law, which acknowledges that: “Scenarios to achieve the temperature targets of the Paris Agreement rely heavily on negative emissions”. The briefing reference the European Academies’ Science Advisory Council (EASAC) Policy report 35 from 2018 . Bellona Europa highlighted the same Policy paper’s findings to the European Commission in the aforementioned consultation replies. We find it necessary to remind the European Commission that while NETPs will have a role to play in the plan to achieve climate neutrality by 2050, it cannot be perceived as a silver bullet. As noted by the EASAC: “Climate scenarios that keep global warming within Paris Agreement limits rely on large-scale application of technologies that can remove CO2 from the air on a huge scale”. They further assert that “…these technologies offer only limited realistic potential to remove carbon from the atmosphere and not at the scale envisaged in some climate scenarios”. We must ensure that the proposed European Climate Law results in absolute emissions reductions and avoid an overreliance on currently unavailable NETPs to reach the set targets. As a first step, there must be a high degree of transparency of trajectories’ reliance on NETPs and their current actual availability of large-scale application. Based on extensive research and expertise on the topic, we present the European Commission with the below 3 recommendations 1. Create and include a robust and evidence-based definition and international standard of what constitutes GHG removal only including permanent removal from the atmosphere. In line with the 4 below criteria : a. Physical GHG are removed from the atmosphere. b. The removed gases are stored out of the atmosphere in a manner intended to be permanent. c. Upstream and downstream GHG emissions associated with the removal and storage process, such as biomass origin, energy use, gas fate, and co-product fate, are comprehensively estimated and included in the emission balance. d. The total quantity of atmospheric GHG removed and permanently stored is greater than the total quantity of GHG emitted to the atmosphere. 2. Amend the proposed Article 3(3) outlining what is to be considered by the European Commission when setting a trajectory in accordance with paragraph 1. Potential overreliance on, and status update of availability of, NETPs for large-scale application should be included as a point in its own right, equal to the other 10 already mentioned aspects to be considered. 3. Bellona Europa repeats its recommendations concerning the inclusion of “benchmark targets” reflecting the current unavailability of NETPs for large-scale application in both the 2030 climate target plan and subsequently in the European Climate Law . We are looking forward to an opportunity to further discuss these recommendations with the European Commission in greater detail, and to provide additional information on the topic of current trajectories’ overreliance on the future availability of NETPs.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Bellona Europa Response to the Inception Impact Assessment on the “Commission Delegated Regulation on a climate change mitigation and adaptation taxonomy” The European Commission’s dedication to a timely finalisation of the planned delegated acts on climate change mitigation and adaptation is commendable in challenging and uncertain times. The final TSCs as included in the delegated acts will define the future role and uptake of the taxonomy, and above all its ability to direct capital to sustainable investment projects. We therefore urge the European Commission to stay true and as close as possible to the recommendations as outlined by the TEG, with particular Bellona Europa recommendations as outlined below. We also urge the European Commission to take note of the latest TEG recommendation from 27th of April calling for the Taxonomy to guide European private and public recovery plans post COVID-19. Technical Screening Criteria Recommendations. It is Bellona Europa’s strong recommendation that the Commission sticks to the single technology-neutral threshold covering all technologies of 100gCO2e/kWh as outlined by the TEG recommendations. This will ensure that unabated natural-gas fired power generation are not seen as sustainable under the taxonomy, and importantly prevent lock-in of assets through investments in accompanying infrastructure. As a long-time advocate for a just transition for all, closely working with the scientific community to ensure achievable outcomes for industrial decarbonisation for decades, Bellona Europa strongly supports the inclusion of CCS as an enabler for reaching the set threshold. This includes the installation of CCS technology being seen as taxonomy eligible once the screening criteria has been met. The science remains clear: deep decarbonisation is not attainable without access to CO2 transport and storage at a large scale. On the issue of the inclusion of CCU technologies in the taxonomy, we recommend that strict sustainability criteria accompany any such inclusion. A full cradle-to-grave LCA of CCU products, including origin of their carbon content, indirect emissions from electricity use and all processing and end-of-life emissions must be considered during their preliminary impact assessment. These recommendations are in line with the “LCA4CCU” report commissioned by DG ENER1. To ensure the credibility, future uptake and legitimacy of the taxonomy, there can be no room for greenwashing or creative accounting practices, especially when considering technologies which haven’t gone through rigorous scientific scrutiny to prove their contribution to climate change mitigation. Keeping in mind the TEG’s outlined recommendation for future considerations by the platform on sustainable finance, it is Bellona Europa’s clear intent to apply for membership to the platform, to offer expertise and important insight and keep the taxonomy credible and free from loopholes or greenwashing potential. Caution when addressing introduction of “Brown Taxonomy” With the stated aim of redirecting much needed investment to sustainable projects, Bellona Europa recommends that the European Commission shows caution when it comes to an early inclusion of a “Brown Taxonomy”. Although there might be a role to play for such a “Brown Taxonomy” in the future, it should be accompanied by a strong legal framework not only reflecting the climate related costs of “Brown Taxonomy” economic activities, but also introducing clear economic consequences for such activities. We believe that an inclusion of a “Brown Taxonomy” at this stage, where a large-scale uptake and usage of the taxonomy is vital for its intended effect, would reduce the legitimacy and credibility of the taxonomy and in its extreme consequence be seen as a tool for greenwashing in providing “less-than-sustainable” economic activities with a stamp of “doing no harm”. Please see attachment for full reply and supporting information
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Response to EU rules on industrial emissions - revision

21 Apr 2020

Bellona Europa fully supports the comprehensive feedback to the Inception Impact Assessment on the Industrial Emissions Directive revision by the European Environmental Bureau and Carbon Market Watch. As the Inception Impact Assessment states, the revision of the Industrial Emissions Directive (IED) should improve its effectiveness and facilitate increased ambition in line with the policies of the Green Deal. The revision of the IED should be used to increase policy coherence and strengthen other goals for industry, such as effective climate action. We support the position of the EEB and CMW which states that the revised IED should support industrial climate change mitigation in a complementary manner to the EU Emission Trading System. More specifically, this entails including greenhouse gas emissions within the scope of this directive by deleting art. 9(1), and amending art. 9(2). By pairing the market-based approach of the EU ETS with the performance-based approach of the IED, the revision could incentivise climate action that has been stagnating under the EU ETS. So far, the EU ETS price signals have proved inadequate in giving the right signal for the decarbonisation of industry. The revision of the IED provides an opportunity to reinforce the current approach, which relies solely on the EU ETS. Since the IED and the EU ETS have a different approach to reducing the environmental footprint of industries, they would reinforce each other. For instance, the Best available techniques Reference documents (BREFs) of the IED would support rather than duplicate the mechanisms in the ETS, since the carbon price is not set on that basis. In the next revision of the Industrial Emissions Directive, we call for: • Deletion of IED Art. 9.1 in order to enable a combined approach of the (IED) as well as market-based instruments (EU ETS); • An amendment to Article 9.2 of the IED to introduce minimal binding (and not optional) energy efficiency standards based on best in class solutions within a given industrial activity (e.g. electricity, heat generation, steel, cement); • Introduction of GHG performance standards to achieve a complete coal and lignite phase-out in the European power and industrial sectors by 2030, and industrial decarbonisation in line with achieving climate neutrality by 2040; • Introduction a Paris Agreement compliance test for new industrial investments and major refurbishments in environmental permitting. This measure would avoid a lock-in of investments into high emitting infrastructure. References: - Carbon Market Watch response to the inception impact assessment on Industrial Emissions Directive revision - European Environmental Bureau response to the inception impact assessment on Industrial Emissions Directive revision - https://carbonmarketwatch.org/publications/carbon-market-watch-input-to-public-consultation-on-the-industrial-emissions-directive/
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

Reducing greenhouse gas emissions in a growing sector such as aviation is becoming increasingly important. While some advanced biofuels (renewable and waste derived) and electro-fuels can reduce emissions in the aviation sector, their use can also lead to an adverse effect. Bellona supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector only if the fuels in question have proven to provide a substantial greenhouse gas reduction. Overall, there are some general principles which should be considered before the introduction of a mandate for a given fuel in the aviation sector. We call for the following factors to be considered for Sustainable Aviation Fuels: - Policy coherence - any support to alternative aviation fuels should be coordinated with other environmental and climate policies. If the measures are not analysed as parts of a wider system of policies, the effects could lead to a harmful outcome (e.g. plastic fuels countering circularity policies). - Full lifecycle assessment - To avoid errors and inform decision making with robust scientific data, a Life Cycle Assessment (LCA) of these fuels should include full chain accounting. This includes the input used in the production process and the carbon embedded in it, CO2 emitted on product use and any additional external effects such as renewable energy displacement or other indirect effects on the system. In other words, both direct and indirect impacts of the fuels should be accounted for (e.g. gCO2eq/kWh for electricity used in e-fuel production, carbon source in waste based and e-fuels). - Deployment potential at scale - The scale of deployment for some of the suggested fuels is limited by their large input requirements. In these cases, trade-offs between direct use of such resources and the production of these fuels on a large scale should be considered (e.g. direct use of renewable electricity in other sectors versus e-fuel production). Example 1: Sustainability criteria for e-fuels (Renewable Fuels of Non-Biological Origin in RED II) The climate impact of an e-fuel depends on the origin of its two main components: 1. carbon (CO, CO2 or other carbon source) and 2. hydrogen. - To account for this effect, we call for the difference between biogenic/atmospheric and fossil carbon to be recognised in the GHG accounting for the fuel. - To account for the indirect climate impact of e.g. hydrogen production for e-fuels and the further reduction in efficiency due to additional processing, we call for the carbon intensity of electricity used to produce the hydrogen to be disclosed (in gCO2eq/kWh) and included in the initial GHG calculations. Example 2: Sustainability criteria for fossil waste-based fuels (Recycled Carbon Fuels in RED II) To determine the GHG impact of waste based fuels, the origin of the waste must be taken into account. Just as biogenic CO2 should be differentiated from fossil, so should the origins of the waste inputs be taken into account: - To account for such potential effects, we call for the initiative not to promote the use of waste-based fuels which rely on fossil waste streams. References: Ramirez et al. 2020. LCA4CCU: Guidelines for Life Cycle Assessment of Carbon Capture and Utilisation. Study for DG ENER, published March 2020, Document reference: LCA4CCU001. https://rethinkplasticalliance.eu/wp-content/uploads/2020/01/rpa_bellona_zwe_counting_carbon.pdf https://zerowasteeurope.eu/wp-content/uploads/2019/04/NGO-joint-briefing-RCF.pdf https://network.bellona.org/content/uploads/sites/3/2019/11/Bellona_CO2-AVOIDANCE-IN-THE-EU-ETS_KEEPING-BUSINESS-AS-USUAL_10_2019.pdf https://network.bellona.org/content/uploads/sites/3/2019/11/Bellona_CO2-AVOIDANCE-IN-THE-EU-ETS_KEEPING-BUSINESS-AS-USUAL_10_2019.pdf
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Response to 2030 Climate Target Plan

15 Apr 2020

Bellona Europa Response to the Inception Impact Assessment for the 2030 Climate Target Plan Bellona Europa welcomes the European Commission’s roadmap for the 2030 climate target plan. The ongoing process and the proposed “European Climate Law” offers an unprecedented opportunity for Europe to become the global leader on tackling climate change. For this to become a reality, however, the proposed impact assessment underlying the 2030 climate target plan must be done right. It is of vital importance to ensure that the intermediate targets enshrined into law through the proposed “Climate Law” are in line with a “just transition for all” as well as sufficient to reach the set target of climate neutrality by 2050. Bellona Europa therefore present the below recommendations, as we see them necessary to ensure that the forthcoming assessment covers all relevant aspects towards a climate neutral Europe by 2050. We ask that the annexes and supporting information included in the PDF attachment is taken into consideration as accompanying this response - in particular our work on the Just Transition Fund and the need for a phase-out of free allocation within the EU ETS. Ensure Absolute Emissions Reduction and clear definition of GHG removal It is of great importance that the proposed impact assessment do not over-rely on uncertain and overly optimistic estimates of the future availability of Negative Emissions Technology and Practices (NETPs) . If such an overreliance occurs, we would fail to reach the set target of climate-neutrality by 2050. We cannot allow ourselves to expect that NETPs will be available at a large-scale within a short timeframe. Bellona Europa therefore draws the European Commission’s attention to the current omission of this important aspect in the published inception impact assessment. Bellona recommends that NETPs be applied as ‘supplementary measures’. As postponing action is not an option, we strongly recommend that the European Commission: 1. Create and include (both in inception impact assessment and resulting amendment to proposed “European Climate Law”) a robust and evidence-based definition and international standard of what constitutes GHG removal only including permanent removal from the atmosphere. In line with the below criteria : a. Physical greenhouse gases are removed from the atmosphere. b. The removed gases are stored out of the atmosphere in a manner intended to be permanent. c. Upstream and downstream greenhouse gas emissions associated with the removal and storage process, such as biomass origin, energy use, gas fate, and co-product fate, are comprehensively estimated and included in the emission balance. d. The total quantity of atmospheric greenhouse gases removed and permanently stored is greater than the total quantity of greenhouse gases emitted to the atmosphere. 2. Include a detailed outline of the 2030 climate target plan’s reliance on NETPs 3. Include a EU “benchmark” emission reduction target for 2030 to reach 2050 target of climate neutrality not reliant on NETPs 4. Include both targets from recommendation 2 and 3 in the proposed 2030 climate target plan and resulting amendment to proposed “European Climate Law” 5. Set clear and enforceable regulation on accounting practices and disclosure requirement actively combatting “creative accounting” practices and greenwashing. We are happy to assist and provide additional information on the topics should it be of further interest. And look forward to following the development of the legislative files as here outlined, also in footnotes, closely.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

Response to the published Inception Impact Assessment for a Carbon Border Adjustment Mechanism Bellona Europa commends the European Commission’s ongoing efforts to ensure that climate neutrality is met by 2050 and efforts to price Greenhouse Gas (GHG) emissions. While the proposed Carbon Border Adjustment (CBA) Mechanism could be an important tool ensuring that imports “reflect more accurately their carbon content”, it must be accompanied by an equally effective carbon price within the EU. With the CBA set to tackle carbon leakage, it must be acknowledged that current levels of carbon leakage are minimal, and any potential future threat hinges on increased asymmetries in global climate ambition levels and carbon prices. Although a CBA could be an important tool in such a context, incentivising global climate ambition levels, it cannot be seen as a silver bullet. In the context of the EU ETS, a CBA is preferable to the current system of free allowances. It is important to note that free allowances cannot operate together or in conjunction with a CBA on the same products. It would either result in not being WTO compliant through double protection of domestic industry, or reduce its effect as any benefit derived from free allowances would also be extended to imports. As the current threat of carbon leakage is minimal, free allowances under EU ETS are resulting in windfall profits rather than protecting against actual carbon leakage. As a result, the current system may in fact contribute to steering investments away from the EU, in particular from decarbonisation efforts. In the upcoming revision of the EU ETS, Bellona Europa strongly recommends that the European Commission complete a full phase-out of free allowances, introduce a price floor and ensure a strengthened and dynamic Market Stability Reserve (MSR) to account for market developments. Although a proposed CBA on imports can be an enabling tool for global climate ambition, it is not sufficient on its own. A CBA mechanism must therefore be accompanied by a comprehensive policy package incentivising low carbon investments, production and consumption within the EU. This must include a portfolio of measures including market drivers for uptake of clean products. Bellona Europa urges the European Commission to include a thorough assessment of all available policy options and tools in the upcoming impact assessment, including the introduction of product standards. Above all, any CBA or policy influencing the treatment of imports must be for climate and not protectionism. The aims below must be at the heart of any potential CBA for it to deliver. If not, a CBA on imports risks being nothing more than a vaguely disguised protectionist measure where global climate ambition and emission cuts are secondary targets. 1. Encourage and incentivize third countries to increase climate ambition to access the European market. In turn reducing total global emissions and facilitate the development of low-carbon products and markets. 2. Facilitate development of low-carbon products and markets in Europe, through sustained demand and predictability, for industries facing “like” cheaper carbon-intensive imports. In turn facilitating further sustainable investment and growth as outlined in the European Green Deal, and also in line with the “just transition for all”. Lastly, a CBA must take “common but differentiated responsibilities and respective capabilities” into account, and resulting revenue should be earmarked to reach set the aforementioned aims, with a particular focus on Least-Developed Countries (LDC).
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Response to Commission Implementing Regulation on the Modernisation Fund

16 Mar 2020

Response to Consultation: “Making energy systems greener – EU Modernisation Fund (detailed rules)” Bellona Europa welcomes the proposed implementing regulation laying down the detailed rules for the application of Directive 2003/87/EC as regards to the operation of the Modernisation Fund. As a long-time advocate for a just transition for all, the Modernisation Fund is seen by Bellona Europa as an important step in the right direction. The Modernisation Fund must deliver on its aim to: “support investments in modernising energy systems and improving efficiency in certain Member States” while contributing to the attainment of the objectives of the European Green Deal. It is Bellona Europa’s view that there are certain aspects of the legal text that need amending for this to be ensured, and we therefore present the European Commission with the following recommendations. Recommendation 1: Investment Committee Clarification and Amendments Needed -Composition To ensure safeguards and oversight, it is important that the biannual meetings of the Investment Committee is open to relevant stakeholders affected by the transition to a climate-neutral economy. The proposed regulation opens for this through its Article 11(6). It is the recommendation of Bellona Europa that there be an amendment specifying that observer status and speaking rights are extended to representatives and stakeholders with proven relevance to the projects in question. This process should be open and transparent, in line with Directive 2003/87/EC Article 10d(5) first sentence of second paragraph. Therefore a “call of interest” should be published well-ahead of the proposed meetings of the Investment Committee, circulated broadly. - Ensuring safeguards through mandatory EIB endorsement of investments In the event that a proposed “non-priority” investment is not endorsed for financing by the EIB representative, Directive 2003/87/EC Article 10d(6-7) removes the voting right of both the EIB representative and the representative of the MS where the investment is to take place. Subsequently, the Investment Committee can make a decision with a two-thirds majority. This raises several concerns, as the EIB’s endorsement is an important safeguard ensuring that the funds allocated under the Modernisation Fund are in fact going towards achieving the stated aim. Bellona Europa therefore strongly recommend that there be an amendment to the proposed regulation establishing further safeguards when it comes to both “non-priority” investments not requiring EIB endorsement, and the exception included in Article 10d(1) second paragraph last sentence. This should be seen as aligning with the regulations’ paragraph (13) highlighting the importance of “clear monitoring and reporting arrangements”. The amendment should establish the necessity of EIB endorsement for all investments, aligning with Directive 2003/87/EC paragraph (16) noting that: “due account should be taken of the expertise of the European Investment Bank (EIB) in the decision-making process”. Recommendation 2: Ensuring EU Sustainable Finance Taxonomy Alignment In line with the proposed regulation’s paragraph (12) referencing Directive 2003/87/EC Article 10d(3), the asset management guidelines to be developed by the EIB should reference and ensure alignment with the EU Taxonomy on Sustainable Finance. This is in line with the goal of the EIB to be the “Climate Bank” of the Union, as well as with the aims of the fund and with the transition towards a climate-neutral economy.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

12 Mar 2020

Bellona Europa comes out in strong support of the aims underlying the proposed regulation 2020/0006 (COD) establishing the Just Transition Fund (JTF). For the transition towards a climate-neutral economy to be successful, it must be a just transition for all. It is imperative that regions facing the greatest challenge have access to technical assistance and funding to ensure climate compliant continued employment and job creation, and sustainable growth. The European Commission has taken an important first step to establish a framework facilitating such support. In the context of the proposed regulation, Bellona Europa reiterates that the phase-out of carbon-intensive industry and economic activity must be completed in conjunction with efforts to phase-in sustainable alternatives. It is through such parallel efforts Europe stands the best chance to mitigate job losses and foster sustainable economic growth. If not properly incorporated into the JTF, we miss an unprecedented opportunity to facilitate a just transition for all to a climate-neutral economy. As a long-time active advocate of a just transition for all, Bellona Europa offers up 4 recommendations in light of the proposed regulation. Recommendation 1: Protecting the welfare of European workers and sustainable economic growth through CCS for low-carbon Steel and Cement facilities Bellona Europa supports the efforts made by the European Commission in the proposed regulation’s Article 5, in particular point (d) ensuring that funding from the JTF does not go to fossil fuel investments. Although imperative to ensure JTF’s contribution to deep and actual industrial decarbonisation, we are concerned that the wording as it currently stand could lead to a lock-out of investments to CCS for low-carbon steel and cement facilities – an important tool relied on in the plans to reach climate neutrality by 2050. We therefore recommend that the regulation is amended to specify that Article 5 do not exclude such investments in CCS connected to low-carbon steel and cement industry. Such climate compatible investments are in fact key to ensure continued employment hand-in-hand with sustainable growth. Recommendation 2: Foster Private Investment through Clarity and EU Taxonomy Alignment To ensure long-term dedication and facilitation of sustainable investments, the JTF and Just Transition Platform should seek to incorporate alignment with the final EU taxonomy once finalized. The proposal’s inclusion of the possibility to increase ambition level and funding in the future is encouraging, as there is little doubt that the transition in full will require funding greatly exceeding the proposed “fresh funding” of €7.5 billion. In this context, we urge the European Commission to ensure clarity as to what extent transfers from funds under Cohesion Policy and national co-financing are included in the SEIP EU budget spending of 25% on climate-related activities. We need a clear grasp on both the challenges and opportunities lying ahead – and in a context where both private and public investment is sorely needed we must foster investor confidence and trust through predictability and clear information. Recommendation 3: Ensure open and transparent process through the Just Transition Platform To ensure that the Just Transition Platform fulfills its promised function to foster cooperation partnership and exchange of best practices, building on the existing platform for coal regions in transition, it is imperative that it is open to representatives of civil society. In particular civil society representatives active in or with relevant experience from the regions eligible for support under the JTF. Such organisations, in additional to EU, national, regional and local stakeholders, should not only be allowed but welcomed and encourage to take part in the work of the platform.
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Response to Climate Law

6 Feb 2020

Please see attachment for full feedback with supporting documentation and sources. The proposed “Climate Law” offers an unprecedented opportunity for Europe to become the global leader on tackling climate change. For this to become a reality, however, the “Climate Law” needs to be done right. In this context Bellona Europa urges the European Commission to set forth a strong legal framework ensuring actual emissions reduction in absolute terms. It is the European Commission’s responsibility to ensure that the intermediate targets enshrined into law through the proposed “Climate Law” do not over-rely on uncertain estimates of the future availability of NETPs. If such an overreliance were to occur, we would fail to reach the set target of climate-neutrality by 2050. Postponing action is not an option, and this is why Bellona Europa sets forth the following concrete recommendations for the European “Climate Law”: 1. Create and include a robust and evidence-based definition and international standard of what constitutes GHG removal in the “Climate Law”, only including permanent removal from the atmosphere. 2. Set clear and enforceable regulation on accounting practices and disclosure requirement actively combatting “creative accounting” practices and greenwashing 3. Include a detailed outline of the current EU intermediate emission reduction target’s reliance on NETPs in the forthcoming and future impact assessments 4. Include an EU intermediate “benchmark” emission reduction target not reliant on NETPs in the forthcoming and future impact assessments 5. Include both targets from recommendation 3 and 4 in the proposed “Climate Law”
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Response to A new Circular Economy Action Plan

20 Jan 2020

See attached document
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Response to European Partnership for Clean Hydrogen

27 Aug 2019

Hydrogen is well placed to replace fossil natural gas, aiding decarbonisation of heating, industry and long-range transport. It is a resource that, if produced and used in a renewable manner, can play a role in tackling emissions of various sectors. However, manufacturing low- and zero-emission hydrogen on a considerable scale will be challenging, particularly in the coming decades. While deployment at scale is needed to drive prices down, large scale deployment of hydrogen production at this point in time could cause a net increase in emissions due to the emission intensity of electricity grids in Europe. In order to avoid this damaging effect and prevent competition with direct use of RES, the production of hydrogen should be amped up in parallel to the deployment of additional renewable electricity. Due to such circumstances, it is imperative that various industries don’t rely exclusively on the unlimited availability of renewable hydrogen in the near future as they currently do [10, 11] . As with all other climate change mitigation options, overreliance on alleged ‘silver bullets’ should not be encouraged. Furthermore, low- or zero-carbon renewable hydrogen should be used directly where possible. Some stakeholders argue that it renewable gases should include methane and other liquid or gaseous hydrocarbons produced by pairing hydrogen with fossil (industrial) CO2. However, relying on such processes would result in a mere transfer of CO2 emissions – the emission would be moved over the fence from one part of the system to another and valuable renewable hydrogen would be wasted to do so. Please get in touch should you have any further questions. Ana Serdoner ana@bellona.org References: [1] Bundeskartellamt, “Monitoring report 2017 - key findings,” Bundeskartellamt, 2017. [2] AGEB, “Energy Consumption Increases Slightly in 2017. No. 05|2017,” AGEB, 2017. [3] Koj, Wulf, Schreiber and Zapp, “Site-Dependent Environmental Impacts of Industrial Hydrogen Production by Alkaline Water Electrolysis,” energies, 2017. [4] Agora Energiewende 2018. [Online]. Available: https://www.agora-energiewende.de/en/topics/electricityproduction/ [5] K1MET, “Energy in Future Steelmaking,” EU Seminar “European Steel: The Wind of Change”, Brussels, 2018. [6] The Royal Society, “Policy briefing: Options for producing low-carbon hydrogen at scale,” 2018. [7] National Research Council; National Academy of Engineering, “The Hydrogen Economy: Opportunities, Costs, Barriers, and R&D Needs,” THE NATIONAL ACADEMIES PRESS, Washington, D.C., 2004. [8] The Royal Society, “Options for producing low-carbon hydrogen at scale,” The Royal Society, 2018. [9] HP, “CO2 capture from SMRs: A demonstration project,” Hydrogen Processing, 2012. [10] Thyssenkrupp, ‘Hydrogen instead of coal. thyssenkrupp Steel launches pioneering project for climatefriendly steel production at its Duisburg site’’, 2019. Available at: https://www.thyssenkrupp-steel.com/en/newsroom/press-releases/press-release-110080.html [11] Salzgitter, ‘’SaltgitterClean Hydrogen’’, 2018. Available at: https://www.salzgitter-ag.com/en/press/press-releases/press-release-of-salzgitter-ag/2018-10-30-1/salzgitter-clean-hydrogen.html
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Meeting with Adalbert Jahnz (Cabinet of Vice-President Maroš Šefčovič)

22 May 2019 · Meeting with Dr Sweeney, Chairman of Zero Emissions Platform - CCUS and long-term decarbonisation

Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

Bellona welcomes a review of the directive on the deployment of alternative fuel infrastructure. The directive, while well-intentioned, currently risks promoting the deployment of fuel infrastructure which is not compatible with the long-term goal of a net-zero transport sector and wider economy. The current directive encourages the deployment of several energy carriers which are fossil fuels and not carbon free, and thus risks delaying the urgently needed decarbonisation of the transport sector. It is also becoming outdated in light of technological and market developments. Incompatible with the Paris Agreement Natural gas and liquefied petroleum gas are fossil fuels emitting greenhouse gases and cannot play a long-term role in the decarbonisation of transport. If the Commission promotes these fuels, it must ensure they only play a temporary role and plan for their phasing-out. Additionally, some synthetic fuels are carbon-based and highly energy intensive, requiring vast amounts of clean electricity, which could be better applied through direct electrification. The direct use of renewable electricity in electric motors is significantly more efficient in providing emission reductions. The source of the carbon used in synthetic hydrocarbon fuels must also be considered; for carbon-neutral fuels to be produced, the carbon must be biogenic (through direct air capture or sustainably sourced biomass). Synthetic hydrocarbon fuels made with fossil carbon are incompatible with the climate goals of the EU and should not be considered as renewable. As such, the inclusion of the above fuels in the AFI Directive runs counter to the long-term goal of economy-wide decarbonisation. A full LCA of energy carriers is needed to ensure that only fuels compatible with net-zero can be included in future legislation. This is particularly important for the AFI Directive, which has been subsequently referred to in the Clean Vehicles Directive, therefore tarnishing that legislative file with incompatible energy carriers and encouraging the public procurement of potential stranded assets. Future proof The AFI Directive failed to account for future technological developments in electrification. An example is the definition of a ‘high power recharging point’ at 22kW, which is by no means ‘high power’ anymore, given most fast-chargers transmit power at over 150kW, with some ‘ultra-fast’ charging supplying at higher powers. It is critical that the AFI Directive ensures interoperability and even coverage of infrastructure between and within Member States. This was raised in the Commission’s assessment of the NPFs. Furthermore, the uptake of electro-mobility has been faster than expected and the Commission should reassess its ‘charger to vehicle’ ratio of 1:10 to ensure sufficient coverage. Coherence and funding The AFI Directive should use the substantial CEF Transport financial envelope, in particular with funding from the Cohesion Fund, to encourage the deployment of infrastructure in Cohesion Fund countries, where uptake of alternative fuels has been insufficient. Bellona looks forward to further contributing to the review process at a later stage.
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Response to Evaluation of the 2011 White Paper on Transport

7 Mar 2019

Bellona welcomes the revision of the 2011 White Paper given the significant developments which have occurred in the past 8 years. Please find our feedback attached.
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Meeting with Miguel Arias Cañete (Commissioner)

27 Nov 2018 · EU Climate policies in the light of the Long-Term Strategy

Meeting with Miguel Arias Cañete (Commissioner) and

29 Apr 2015 · CCS presentation to the Commissioner