ENERTRAG
ENERTRAG provides all services related to renewable energy.
ID: 186190042949-20
Lobbying Activity
17 Jun 2022
General remarks:
As a European renewable energy company and green hydrogen producer with sites in Germany, France and Poland as well as in Africa, Asia and Latin America, ENERTRAG supports the ambitious European CO2 reduction targets and the transformation of the energy sector. The recast Renewable Energy Directive in-troduces new provisions for promoting the use of renewable liquid and gaseous transport fuels of non-biological origin (RFNBOs) and recycled carbon fuels (RCFs). To support the introduction of these advanced fuels into Europe’s transport fuel mix, the Delegated Act (DA) pursuant to Article 25(2) and Article 28(5) of the EU RED II is to clarify the minimum GHG savings required for RCFs and set out a methodology for the calculation of GHG associated with RFNBOs and RCFs (Ref. Ares(2022)3836721).
However, in its current form, the draft DA leaves a number of issues and specific circumstances unaddressed that could unlock investment in repurposing CO2-intense existing fuel production assets to bring initial RFNBOs and RCFs to market in the quickest and most cost-efficient way, while providing a key stepping stone in the global energy transition. The main criticism of the pro-posed GHG calculation methodology is that it does not provide the requisite flexibility in emission reduction allocation that would facilitate the decarbonisa-tion of incorporated processes such those in Fischer-Tropsch plants. This risks disincentivising gradual replacement of fossil inputs with green hydro-gen and suitable recycled carbon in such installations, as none of their products can meet the GHG savings thresholds until all of them do.
At the same time, the draft DA in its current form risks potentially locking in fossil pathways as suppliers of CO2 for the production of carbon-based RFNBOs in sectors where deep decarbonisation can be achieved faster than a return on an investment in a RFNBO production facility. This is particularly the risk in the electricity sector. There are sufficient sources of unavoidable CO2 emissions in the production of bunker fuels, chemicals, cement and other industrial processes that will be harder to decarbonise in the middle term that should be the target of CO2 capture and utilisation, but where the timeline needs to be extended to allow for a viable investment case.
Enertrag therefore advocates that the EU climate and energy transition objec-tives would be better served by a smaller pool of candidate emission streams with longer utilisation timelines and flexibility for the initial quantities of RFNBOs and RCFs to be recognized in instances of incorporated co-processing.
Concrete need for refinements in the Delegated Acts please find in the enclosed document.
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