Global Alliance Powerfuels
The strategic objective of the Alliance is to foster the development of a global market for powerfuels.
ID: 364985141054-10
Lobbying Activity
17 Jun 2022
The Global Alliance Powerfuels welcomes the opportunity to comment on the European Commission’s proposal for the methodology to assess the greenhouse gas (GHG) emissions savings from renewable fuels of non-biological origin (RFNBOs) and recycled carbon fuels, which can provide much-needed regulatory certainty by setting out rules for the eligibility and accounting of different inputs, establishing a fossil fuel comparator, and hence defining the maximum life cycle GHG emissions of different RFNBOs.
The details of the methodology will have a significant impact on the future development of the powerfuels market within the EU and in non-EU countries. Therefore, the provisions therein need to be transparent and comprehensive, and ought to ensure that adverse incentives leading to unsustainable production practices are avoided.
The Global Alliance Powerfuels recognises many important elements in the proposed draft of the D.A., and generally supports the defined system boundaries for calculating the total emissions from RFNBOs and suggestions made for avoiding double-counting of emission reductions. However, we see a need to add clarification, e.g. on how to assess the emission savings from RFNBOs co-processed with fossil inputs, and to differentiate further between different potential sources of CO2 for the production of carbon-based powerfuels, to exploit the full potential of the D.A. to support the sustainable market development of RFNBOs.
Specifically, to provide more clarity on how to calculate and account GHG emissions savings from co-processed RFNBOs, the D.A. should more explicitly allow for the volume of the finished product(s) to be administratively quantified into notional non-renewable and renewable portions with different respective GHG intensities. With regard to the accounting and eligibility of CO2 from different sources as an input for the production of RFNBOs, the Global Alliance Powerfuels suggests excluding fossil power generation installations from the get-go and bringing forward the phase-out of avoidable industrial emissions to 2030, while implementing strict criteria to allow for more flexibility for the use of CO2 that stems from unavoidable industrial emissions, which could remain an eligible carbon source beyond 2030.
Please find our detailed feedback attached.
Read full responseResponse to Revision of EU rules on Gas
13 Apr 2022
The Global Alliance Powerfuels welcomes the revision of the EU Gas Directive and the Gas Regulation and endorses the European Commission’s goal to support the EU's delivery of its strengthened climate targets by facilitating the gas market integration of renewable and low carbon gases, including renewable hydrogen and other renewable fuels of non biological origin (RFNBOs).
Enabling and accelerating the transition away from fossil fuels has become even more urgent in view of Russia’s unjustified and unprovoked invasion of Ukraine. Measures included in the package, e.g. to incentivise the import of renewable and low carbon gases via pipelines as well as LNG terminals, can contribute to speeding up this transition and reducing the dependency on natural gas imported from Russia. However, in view of the EU’s increased renewable hydrogen ambition regarding both the targeted production volumes in Member States and those of imports, some of the proposed provisions, e.g. on the regulation of hydrogen network operators and the timeline for specifying GHG requirements for low carbon and renewable gases, should be re-evaluated to enable the needed mobilisation of financial and technical resources, in particular in the early powerfuels market development phase.
Please find attached our detailed feedback.
Read full responseResponse to Revision of the Energy Tax Directive
18 Nov 2021
The Global Alliance Powerfuels welcomes the much-needed revision of the EU Energy Taxation Directive (ETD) and endorses the European Commission’s goal to support the EU's delivery of its climate targets by drafting an adequate taxation scheme that recognises the environmental performance and promotes the market integration of renewable energy carriers, including RFNBOs.
Please find our detailed feedback and recommendations attached.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
18 Nov 2021
The Global Alliance Powerfuels welcomes the much-needed revision of the revised Renewable Energy Directive (REDII) and endorses the European Commission’s goal to establish a regulatory framework that sets adequate incentives for the market integration of renewable energy sources and carriers, including renewable hydrogen and other renewable fuels of non biological origin (RFNBOs).
It will be essential to amend and implement the targets of the directive as quickly as possible and thus accelerate the use of renewable energy in all sectors. Supported by a consistent specification of climate-friendly economic activities in the EU Taxonomy, this can contribute to avoiding misdirected investments at an early stage and choosing the most cost-effective path to climate neutrality. In addition, the revision of the REDII to align it with the goals of the European Green Deal can also accelerate the transition to a more integrated energy system and contribute to delivering the goals of the European hydrogen strategy.
Please find our detailed feedback and recommendations attached.
Read full responseResponse to Updating the EU Emissions Trading System
8 Nov 2021
The Global Alliance Powerfuels welcomes the revision of the EU Emissions Trading System Directive and endorses the European Commission’s goal to enable Member States to fulfil the EU's climate objectives of the European Green Deal in a cost-effective way by strengthening the scale
and scope of carbon pricing in the EU. Please find attached our detailed feedback.
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