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Johanssen+Kretschmer Strategische Kommunikation GmbH

Johanssen + Kretschmer berät Unternehmen, Verbände und weitere Akteure zur strategischen Positionierung und Kommunikation im politischen und vorpolitischen Raum.

Lobbying Activity

Response to Greenhouse gas emissions savings methodology for recycled carbon fuels and renewable fuels of non-biological origin

17 Jun 2022

The European Commission has published a draft delegated act to establish a methodology to assess greenhouse gas (GHG) emission savings from RFNBOs and recycled carbon fuels (RCFs). The Power to X Alliance welcomes the largely technology-open design of the delegated act but sees a need for adjustment regarding the following points: The use of green hydrogen can make an essential contribution to climate protection in refineries. To this end, the delegated act should clarify how to deal with GHG reductions resulting from the replacement of grey hydrogen with green hydrogen in refineries for hydro treatment of conventional fuels. The regulation should also clarify how the share of renewable energy in green hydrogen counts towards the target in Article 25 RED II. Number 11 of the Annex to the delegated act allows captured CO2 to be incorporated into the fuel before 2036. The delegated act should allow carbon capture at unavoidable industrial sources also after 2036. Number 15(f) of the Annex defines that where a process yields multiple co-products, the ratio of the products is fixed and some co-products are materials not used for fuels, the allocation of GHG emissions shall be done by the economic value of the co-products. However, an allocation by economic value would create unnecessary difficulties and additional administrative burden as not all product prices are easily available. Therefore, an allocation by energy content would be more reliable and easier to administer. We would be most grateful if you would take our concerns into account and will be glad to assist you with any questions you might have on our recommendation.
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