LanzaTech EU B.V
LanzaTech
LanzaTech’s gas fermentation technology produces fuel grade ethanol that can support Europe's renewable energy goal for transport.
ID: 569758814806-70
Lobbying Activity
Response to Delegated act on primarily used components under the Net-Zero Industry Act
14 Feb 2025
Carbon capture and utilisation company LanzaTech welcomes the publication of the Draft Delegated Act but notes the Annex is incomplete. Specifically the Annex entirely omits technologies for the production of Recycled Carbon Fuel that are part of the Renewable Energy Directive (RED) and are an important feedstock for SAF. The annex makes multiple mention of the utilisation of biogenic feedstock in several sub-categories, including biotechnology, and also of RFNBOs, but is incomplete in recognising facilities that capture and reuse waste fossil carbon oxides (CO and CO2). The Annex should be made consistent with facilities that produce RED compliant products.
Read full responseResponse to Permanent storage of EU ETS emissions through carbon capture and utilisation
12 Jul 2024
LanzaTech is disappointed by the approach proposed by the Commission that, if implemented, will slow the development of carbon capture and utilization (CCU), a strategic technology in the delivery of the EUs ambitious net-zero climate goals. Specifically, LanzaTech objects to the imposition of EU Emissions Trading Scheme (EUETS) costs on captured, recycled carbon (from CO2) used as feedstock in the chemicals industry whilst equivalent virgin fossil feedstock (that represents 93% of the EU-market) incurs no costs. LanzaTech calls for the Commission to delay changes to the way captured carbon is accounted for until the next revision of the EUETS that is due to be consulted upon in 2026 and implemented by 2030. This revision will address a range of important considerations impacting on CCU processes including how to allocate end of life emissions arising from captured carbon; the planned inclusion of waste disposal in the EUETS; and should also include how to account for fossil carbon embedded in chemicals. Delaying the implementation of the rules will have insignificant consequences for the exactness of the EUETS compared to total EUETS emissions in 2030. A delay to imposing EUETS costs (where carbon is temporarily stored) will however enable the CCU sector to deploy more facilities in the period to 2030 enabling more rapid growth and lower costs to be achieved in the post 2030 period. The Commission proposal puts principle ahead of practicality and in the process eliminates the incentive to capture carbon that could be recycled to reduce use of virgin fossil materials in sectors like chemicals. It is a proposal that is counterproductive, inhibiting the EUs ability to meet its long-term climate goals by creating an unnecessary barrier to the development of CCU, for no meaningful benefit; and, will lead to a great use of virgin fossil feedstocks and more emissions. If the Commission is unwilling to reconsider this proposal the European Council and Parliament should reject this il-considered regulation.
Read full responseResponse to Carbon capture utilisation and storage deployment
31 Aug 2023
LanzaTech is a carbon capture and transformation company that uses a biocatalyst to recycle waste carbon to produce ethanol and other chemicals as a substitute for virgin fossil carbon feedstock. The first European facility using this technology, Steelanol will shortly begin production at the ArcelorMittal steel mill in Gent, Belgium. The LanzaTech process is agnostic to the origin of the carbon. LanzaTech is pleased that the Commission has initiated a consultation but disappointed the outline Strategy fails to fully recognise the opportunities presented by carbon capture and utilisation or address the barriers to its development. It is notable the Call for Evidence largely focuses on CCS and makes no mention of creating a market for recycled carbon products to support a circular carbon economy. The Strategy must include targets for CCU and propose regulations to drive uptake of CCU products in the chemicals, plastics and construction products sectors. In Europe, 93% of the carbon embedded in the chemical and derived materials industry is sourced from virgin fossil feedstock by 2050 this needs to change. By recycling above ground waste carbon, LanzaTech products substitute virgin fossil carbon with greenhouse gas savings of around 70%. But the Call fails to build on the Sustainable Carbon Cycles Communication and aspiration that "at least 20% of the carbon used in the chemical and plastic products should be from sustainable non-fossil sources by 2030". We understand this to mean a push to avoid virgin fossil extraction and leverage existing sources of waste carbon that can replace virgin fossil inputs with no compromise on product integrity, security of supply, biodiversity impact or indirect land use change. New regulation is needed along the lines of a cap and trade scheme for the carbon embedded in products. The Call for Evidence correctly observes current policy has not been sufficient to deploy CCU at scale. The development of the market is hampered by: the absence of regulation to require a shift from virgin fossil to renewable and recycled carbon sources in chemicals and plastic; the relatively small scale of current production and immaturity (and therefore high cost) of the technology; the absence of any carbon price being applied to fossil feedstock; and, most importantly, the overly complex and excessively cautious European regulation of CCU products. For example: the sunset clause for use of fossil carbon means technologies will not receive investment to start deploying technology to get down the cost curve. Requirements that carbon feedstocks must have an effective carbon price prevent the use of carbon oxides from MSW and the import of feedstock from most of the world. Meanwhile onerous and anomalous GHG accounting practices make it very expensive to meet required GHG savings. The ETS requirement that carbon must be permanently stored to be considered captured creates a further barrier. The Commission has failed to see the need for CCU as this Call illustrates and has dropped the ball on encouraging CCU technologies. When the Strategy is prepared there needs to be a new focus on the opportunities CCU for both the climate and Refuel EU initiative. Carbon management is not just about abating emitted carbon. It is about replacing virgin fossil carbon in the materials that we use every day and that can only happen with the support of CCU technologies. LanzaTech is a global business and the regulatory barriers being created in the EU make other markets more attractive for investment including the US, India, China the Middle East and UK. The forthcoming Strategy provides an opportunity to put the EU on a pathway to become a world leader in the development and deployment of CCU technologies. If this Strategy fails to deliver LanzaTech will capture carbon in places that recognise the added value of recycling carbon and dont want to just landfill a valuable resource through CCS.
Read full responseMeeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson) and Chelgate Limited
17 Oct 2022 · Renewable Energy Directive
10 Jun 2022
LanzaTech, is a global company with a registered business in the Netherlands and offices EU-wide. Its gas fermentation technology uses biology to recycle waste carbon into ethanol; this is converted into sustainable aviation fuel (SAF) using the LanzaJet™ Alcohol to Jet process. By capturing and reusing waste carbon emissions for fuel production EU imports of fossil resources are reduced, helping to deliver the EU Fit for 55 targets; and RePowerEU goals.
LanzaTech is dismayed by the European Commission’s Draft Delegated Act which, as drafted, would limit the production Recycled Carbon Fuels (RCFs) from industrial processes, like steelworks, to just 8 EU Member States (Croatia, Denmark, France, Luxembourg, Portugal, Slovakia, Spain, and Sweden) for just 10 years. This reduces investment and jobs in clean technology; and is contrary to the aims of the single market. To enable production of RCFs Union-wide two modest amendments are proposed:
1. To Annex I, 10a, a change to the GHG-accounting method to allow purchased renewable energy (that meets additionality requirements) to replace any displaced electricity production. The Commission proposal requires displaced energy to be replaced with grid-electricity in the country in which the RCFs are produced. The high carbon intensity electricity in many member states prevents the 70% GHG-saving threshold being reached in half of EU Member States until after 2030.
With the amendment, Renewable Energy Directive (RED) credits can be generated for RCFs in almost all EU Member States immediately. Alignment between the RCF and RFNBO accounting methods is also retained. The change also leads to increased renewable energy generation; higher GHG-savings; increased investment and jobs; and enables more SAF production and use in the EU - a triple win for the environment, economy, and energy security.
2. To Article 7 and the related Annex 11a we propose a deletion of the end date for using fossil fuels as feedstocks. The proposal is premature and will not discourage lock-in to fossil fuels by industrial processes. However, as drafted it will prevent earning RED credits for the capture and use of ALL the remaining CO2 emissions from processes within the Emissions Trading Scheme after 2035. This was not the intention of Article 28 (5) of the RED II which is the basis for this Act. The implementing clause only asks the Commission to develop a greenhouse gas accounting method that avoids double counting; there is no mention of specifying an end date for avoiding emissions; or, defining what constitutes “non sustainable fuels”.
LanzaTech fully supports the 2050 Net Zero goal. But fossil waste carbon from industrial sources will continue to be emitted for more than a decade after 2035 and could be valuably recycled. Any end date should align better with the 2050 net zero objective’ and avoiding lock-in to fossil fuels through carbon capture and use should be addressed through forthcoming legislation on sustainable carbon cycles.
Other inconsistencies and issues with the draft DA are provided in our attached detailed response.
The current draft will drive investment, jobs and sustainable fuel production from the EU and reduce sustainable feedstock availability for SAF. Technologies for carbon recycling will be developed and mainly be deployed outside of the EU and SAF which is produced will be used in non-EU markets. By 2030 less than a fifth of the RCF ethanol that could be produced from EU steelworks would qualify for RED certificates under the Commission proposals. With the modest changes proposed 3.5 times higher cumulative CO2 savings are possible by 2030, around 230 million Tonnes CO2e. In addition, the use and import of fossil fuels will be reduced. The proposed Delegated Act is counterproductive, but modest changes can facilitate the development of sustainable RCF technologies as intended by the RED II.
Read full responseResponse to Carbon Removal Certification
29 Apr 2022
LanzaTech welcomes the EU Commission's initiative on Carbon Removals. Carbon Capture and Utilization technologies are an essential pathway to reaching the EU climate goals. By capturing and transforming carbon oxides such as CO and CO2 scalable alternatives to fossil carbon become available to produce fuels and products helping to address both the climate emergency and energy security concerns. Carbon utilization from industrial sources can also reduce future demand for bioenergy avoiding the risk of counterproductive land use change.
Whilst there is huge potential for carbon capture, storage, and utilization technologies, Lanzatech recognize that carbon removals and reuse only play a complementary role to decarbonization technologies that eliminate emissions. Rapid progress in both areas is needed to stabilize the climate and limit global warming to safe levels.
We agree with the Commission that establishing a framework for the certification of carbon removals is an essential steppingstone towards achieving a net contribution from carbon removals in line with the EU climate-neutrality objective. We also recognize the conclusions of the Intergovernmental Panel on Climate Change (IPCC) that we require all solutions and should not continue to emit as normal and then depend on carbon removal technologies in the future. We need to utilize all approaches to reduce carbon in the atmosphere, including avoiding emissions and capturing emissions before they are emitted. LanzaTech looks forward to working alongside the EU Commission during the development of this dossier.
Read full responseMeeting with Jan-Christoph Oetjen (Member of the European Parliament, Rapporteur)
7 Mar 2022 · EU ETS Aviation
Response to Waste Framework review to reduce waste and the environmental impact of waste management
17 Feb 2022
LanzaTech welcomes the EU Commission’s proposal to revise the Waste Framework Directive. The Waste Framework Directive is a crucial legislative instrument to achieve the EU Commission’s goals set out in the European Green Deal and the Circular Economy Action Plan.
The Circular Economy Action Plan commits to significantly reducing total waste generation. More specifically, it aims to halve the amount of residual (non-recycled) municipal waste by 2030, promote safer and cleaner waste streams and ensure high-quality recycling.
Municipal solid waste (MSW) is a growing global problem, and options of how to dispose of it have been limited until now. LanzaTech has developed a new, economically attractive solution that not only reduces greenhouse gas (GHG) emissions compared to incineration, but also enables conversion of MSW into valuable products.
LanzaTech is the global leader in gas fermentation technology and has developed a novel process that uses a living, naturally occurring organism (biocatalyst) to ferment gases to make fuels, such as ethanol and chemicals. A variety of carbon-rich waste gas streams can be used as a feedstock for the fermentation process. With LanzaTech’s solution, MSW or RDF (refuse-derived fuel from MSW) is gasified to produce syngas which is biologically converted to fuels or chemicals.
LanzaTech looks forward to working alongside the EU Commission during the Waste Framework negotiations. LanzaTech would like to propose two initial issues for consideration by the Commission, which we believe will help achieve the aims of the Circular Economy Action plan and those outlined in the Commission’s Impact Assessment.
Read full response18 Jan 2022
LanzaTech welcomes the European Commission's plan to update food-contact plastic regulations to enable safe use of recycled plastic in support of the circular economy.
We note that complete chemical depolymerization processes providing monomers, for example as done by thermal or thermocatalytic processes, appear outside of the scope of this regulation. Clarity is needed that these exempted processes may contribute to recycling quotas and targets for recycled content.
As a technology provider, clarity in definitions are needed as we work with plastic recyclers to provide novel technologies, some of which decontaminate the input material as part of the process, rather than as a separate decontamination step. We note the many important comments from various recyclers on administrative aspects that could be simplified without impacting health and safety.
Read full responseMeeting with Cláudia Monteiro De Aguiar (Member of the European Parliament, Shadow rapporteur)
2 Dec 2021 · Refuel Aviation
Response to Revision of the Energy Tax Directive
17 Nov 2021
LanzaTech commends the European Commission’s ambition in its revision of the Energy Taxation Directive (ETD). We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward. The following outlines our feedback and recommendations on some of the specific policy mechanisms put forth in the EU Commission’s proposal
Supporting a level playing field while reforming fuel and energy taxation is key to get sustainable fuel technologies deployed in the EU. A part of this should be harmonization across the Member States, rather than a fragmented approach with could lead to investor uncertainty and deployment delays.
We believe this revision should adopt a technology neutral approach and support investments in new technologies for sustainable fuels and energy production. The ETD should align the definition of fuels with those as defined in REDII and the proposals for REDIII and should not seek to exclude any category of fuels.
We support performance-based taxation as rewarding outcomes and overall sustainability of a fuel is key to meeting any GHG reduction and sustainability targets. There should not be prescriptive feedstock lists, rather all pathways should be eligible, provided they meet sustainability criteria and/or thresholds to ensure only pathways or fuels with real savings and benefits are supported. We are concerned that some fuel pathways will be excluded or delayed in deploying due to fragmentation or challenges with timings of Delegated Acts (as we have seen with the category of Recycled Carbon Fuels in REDII).
Allowing an energy tax exemption/tax reduction for new approaches is also positive but should again ensure that it is focused on level of commercialization (current volumes available in the market and cost curve progression) rather than focusing on a narrowly defined list of eligible fuels. This will be key in driving a market and providing investor confidence to invest in scale up and to build new facilities in the EU.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
17 Nov 2021
LanzaTech commends the European Commission for its proposal to amend the Renewable Energy Directive (RED). The Renewable Energy Directive is a vital legislative tool to turn the EU's Green Deal ambitions into a reality. We welcome the opportunity to respond to the EU Commission's proposal and working alongside the co-legislators in the future. The following outlines our feedback and recommendations on some of the specific policy mechanisms put forth in the EU Commission's proposal.
Recycled Carbon Fuels
LanzaTech welcome the continued inclusion of “recycled carbon fuels” (RCF) in the revised Renewable Energy Directive (RED). It is a clear indication that the deployment of such fuels is part of a transition to a low carbon economy. These technologies transform unavoidable gaseous waste streams from industrial activities into fuel, without affecting land or water, exist today and can help achieve the EU’s sustainability goals under the green deal.
However, the inclusion of RCFs is still fraught with challenges at an implementation level because it is an opt-in solution for the Member States and has additional technical details to finalize. We would like to see the use of recycled carbon fuels to be allowed for compliance at the Union level rather than leaving this at the discretion of member states which would create a more harmonized approach. Any revisions should create a technology-neutral and level playing field for all sustainable fuel approaches to contribute. We, therefore, ask that the co-legislators treat RCFs in the same manner to which RNFBOs are treated within the RED II revision and ensure that the new Article 29a(1) and the new Article 29a(2) are aligned.
Delegated Acts within RED II
We appreciate the heavy burden placed on the EU Commission in developing delegated acts over the past year. However, we are concerned about the status of the delegated acts contained within the current RED II directive. Specifically, the delegated acts contained within the current RED Article 28(5). The rollout of RCFs is dependent on the development of these delegated acts. We do not have the luxury of time before starting to put steel in the ground to produce new sustainable fuels. Therefore, we ask that the co-legislators set a more ambitious timetable for publishing these delegated acts than is currently envisaged.
Read full responseResponse to ReFuelEU Aviation - Sustainable Aviation Fuels
17 Nov 2021
LanzaTech commends the European Commission for its consideration of policies in support of aviation greenhouse gas reductions and increased supply and offtake of sustainable aviation fuels in the EU. We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward. The following outlines our feedback and recommendations on some of the specific policy mechanisms put forth in the EU Commission’s proposal.
Recycled carbon fuels (RCF)
We were disappointed that recycled carbon fuels are not included in the ReFuel Aviation proposal. We need to create a level playing field for recycled carbon fuels, and SAF policies should promote diversification of pathways and feedstocks. From the standpoint of sustainability, priority should be given to pathways using waste and residue feedstocks, including agricultural and forestry wastes, unrecyclable municipal wastes, and waste industrial process gases.
The ReFuel proposal should develop a technology-neutral and level playing field for all sustainable fuel approaches to contribute. Recycled carbon fuels that are ASTM approved drop-in fuels and fulfil all sustainability criteria under the Renewable Energy Directive should be included in the ReFuel Aviation mandate.
We all want to avoid the unintended consequences of new technologies. Still, safeguards can be built in through monitoring and the use of staged GHG reduction thresholds to ensure that technologies are improving year on year. With the imminent publication of delegated acts (current article 28(5)/revised 29a(3)), setting out the methodology for meeting the 70% GHG reductions savings necessary for RCFs to qualify under the revised RED, recycled carbon fuels provide a sustainable solution.
Future certification
LanzaTech welcomes the EU Commissions initial discussions around the future certification of pathways but urges caution in allowing sustainable solutions that are available today to contribute and not be excluded.
Cellulosic Biomass: The current guidance for non-compliance penalties insufficiently incentivizes the use of cellulosic feedstocks. Due to the difference in cost compared to the use of waste oils, a fuel supplier is only incentivized to start supplying Alcohol-to-Jet and Gasification/Fischer Tropsch-based SAF when feedstocks for the HEFA pathway are completely depleted. Only when the non-compliance penalty reaches the cost of AtJ and G/FT SAF will it become worthwhile to supply those fuels. This can potentially lead to negative effects, such as delaying the moment in which investments in AtJ and G/FT start to make economic sense for the mandate, or the potential diversion of feedstocks from the road transport sector to aviation since the penalty is higher there.
To address this gap, we recommend establishing dedicated funding calls for SAF pathways that are not yet commercially ready, e.g. through contracts-for-difference or the Innovation Fund.
On synthetic aviation fuel:
Looking at the announcements for synthetic aviation fuel production capacity in the EU today, several of these projects intend to start operation before 2030. It is therefore recommended to bring forward any targets to 2027.
Timing is critical for deploying all sustainable solutions and we must act today if we are to meet the volume and GHG targets we need.
Read full responseResponse to FuelEU Maritime
5 Nov 2021
LanzaTech commends the European Commission for its proposal to boost the uptake of sustainable fuels in shipping and ports to reduce emissions from the sector. We welcome the opportunity to respond to the EU Commission's proposal and working alongside the co-legislators in the future. The following outlines our feedback and recommendations on some of the specific policy mechanisms put forth in the EU Commission's proposal.
We welcome the inclusion of Recycled Carbon Fuels within FuelEU Maritime. We need all sustainable solutions to support emissions reductions across the sector. As stated in the proposal, the ‘development and deployment of renewable and low carbon fuels with a high potential for sustainability, commercial maturity and a high potential for innovation and growth to meet future needs should be promoted.’
To facilitate and support the creation of innovative and competitive fuels markets and ensure sufficient supply of sustainable maritime fuels in the short and long term we believe there should be equal treatment between the maritime sector and other transport sectors for all fuels eligible under Directive 2018/2001.
Whilst we appreciate the unique nature of the maritime sector, we are concerned in general that any fuels that don’t meet the requirement of any established thresholds are automatically considered to have the same emission factors as the least favourable fossil fuel pathway for these types of fuels.
Our concern is that if a RFNBO or a RCF, that is already subject to distinct sustainability criteria, doesn’t meet the threshold by a small margin, they are associated with a greater carbon burden by this assessment. We absolutely believe that all fuels should be subject to rigorous sustainability assessments and safeguards should be in place to avoid biodiversity impact and additional GHG emissions but are concerned that real savings may be missed when setting thresholds in place rather than rewarding GHG savings incrementally. RCFs and RFNBOs have a high potential for sustainability and commercial maturity to meet the Green Deal ambitions and should be promoted.
Finally, we understand that Recycled carbon Fuels and renewable fuels of non-biological origin still require Delegated Acts within other EU Legislation (REDII) to determine the GHG reduction of the fuels. We appreciate the heavy burden placed on the EU Commission in developing delegated acts over the past year. However, we are concerned about the status of the delegated acts contained within the current RED II directive. Specifically, the delegated acts contained within the current RED Article 28(5). The rollout of RCFs is dependent on the development of these delegated acts.
Read full responseResponse to Updating the EU Emissions Trading System
4 Nov 2021
LanzaTech commends the European Commission’s ambition in its revision of the Emissions Trading Scheme (ETS). We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward. The following outlines our feedback and recommendations on some of the specific policy mechanisms put forth in the EU Commission’s proposal.
• Carbon Capture and Utilisation (CCU)
LanzaTech welcomes that no obligation to surrender allowances shall arise in respect of emissions of greenhouse gases which are considered to have been captured and utilised to become permanently chemically bound in a product so that they do not enter the atmosphere under normal use, as per Article 12(3)b. CCU technologies avoid the use of virgin fossil resources and help lower the carbon intensity of products. LanzaTech welcomes the EU Commission's proposed Innovation Fund to explore the potential of Carbon Capture and Storage (CCS) and Carbon Capture and Utilize (CCU). We look forward to working alongside policymakers to demonstrate the role of CCU in meeting our sustainability ambitions.
We would like to see the definition of CCU broadened to beyond just carbon dioxide (CO2) to include all carbon oxides such as carbon monoxide (CO) and that all CCU products that chemically bind carbon through CCU technologies should be supported. Furthermore, LanzaTech believes that the benefits of CCU should incorporate other externalities beyond just CO2. As noted in the SAM recommendations to the EU Commission in the Scientific Opinion 4/2018 “the climate change mitigation potential of CCU as a service to energy or industrial systems should be seen not only in terms of CO2 emissions reduction but also in terms of CCU as a service to larger production systems”.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
14 Oct 2021
To meet our climate objectives, we should seek to include all sustainable solutions within the definition of biobased plastics.
This can include solutions that use bioprocessing or biological processes to make products, including plastics and packaging.
The American Association for the Advancement of Science defines bioprocessing as: any process that uses living cells or their components (e.g., bacteria, enzymes, or chloroplasts) to obtain desired products.
Technologies exist today that can use biological processing of waste carbon feedstocks (industrial emissions, captured CO2, unsorted, unrecyclable wastes and residues) to make new materials that would otherwise come from virgin fossil feedstocks. These offer a solution to keep carbon in the material cycle and support a circular economy.
One definition of a similar pathway has been in the revised Renewable Energy Directive, with Recycled Carbon Fuels. This could be used for biobased plastics production as well when combined with the biological processing link:
‘Recycled carbon fuels’ means liquid and gaseous fuels that are produced from liquid or solid waste streams of non-renewable origin, which are not suitable for material recovery in accordance with Article 4 of Directive 2008/98/EC, or from waste processing gas and exhaust gas of non-renewable origin, which are produced as an unavoidable and unintentional consequence of the production process in industrial installations.
A possible definition could be:
Biobased plastics include plastics that are produced via bioprocessing of liquid or solid waste streams of non-renewable origin, which are not suitable for material recovery in accordance with Article 4 of Directive 2008/98/EC, or from waste processing gas and exhaust gas of non-renewable origin, which are produced as an unavoidable and unintentional consequence of the production process in industrial installations.
By including a wider scope of sustainable feedstocks, we allow more chances as reducing the carbon footprint of the materials we make. This approach promotes recycling at the chemical level, with no loss of properties and keeps carbon in the circular economy. Sustainability safeguards can be put in place to monitor the life cycle of the process and to ensure that only sustainable options contribute.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
16 Dec 2020
LanzaTech would like to thank the European Commission for the work done so far and to take the opportunity offered by this consultation to provide some recommendations to this Delegated Act.
Manufacture of biogas and biofuels for use in transport (Annex I, Section 4.13)
Inclusion of liquid and gaseous transport fuels of non-biological origin (RFNBOs) and Recycled Carbon Fuels (RCFs) as they are defined in the REDII to be included under Technical screening criteria, Substantial contribution to climate change mitigation point 1. These can be included as a separated eligible feedstock point.
Carbon capture storage (CCS) and carbon capture utilisation (CCU) (Annex I, Section, 5.11 and 5.12)
Article 10, Section 1.(e) of Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment explicitly cites CCU as a solution that brings a substantial contribution to climate change mitigation. It is therefore a surprise that while the benefits CCU have been acknowledged, several passages in the proposed Delegated Act Annex I create barriers against CCU, and we are concerned that no technical screening criteria for CCU have been developed.
We recommend the inclusion of a new section on CCU applications as Section 5.13. There are techniques that enable capturing carbon oxides released by industrial processes that can convert them into valuable products that would help meet the EU’s Green Deal objectives. In addition, limiting CCU to only CO2 will mean the EU will have missed opportunities for investment into CCU applications that exist today and are operating in different markets. Language around CCU should encompass all carbon oxides that can be captured and utilized to support the objectives of the Green Deal, this is especially important in the references to iron and steel manufacturing which only reference CO2.
CCU in other sections and activities of the Annex.
Despite the citing of CCU in Regulation 2020/852, several passages in the proposed technical screening criteria of the Delegated Regulation do not include CCU when it is clear it would fit and support the objectives of the Taxonomy. In our attached file we suggest where edits supporting CCU woudl fit.
Section 3.5 Manufacture of other low-carbon technologies
Section 3.5 is a natural home to support CCU products and technologies, however the wording is around “manufacture of technologies” rather than manufacture of products, which may support some technology producers deploying CCU facilities in Europe, but doesn’t support the products made in these facilities. Inclusion of CCU products and technologies can be explicitly included in Section 3.5 with the following addition highlighted in bold.
Description of the activity
Manufacture of low carbon technologies and products that result in substantial GHG emission reductions in other sectors of the economy.
Technical screening criteria
Substantial contribution to climate change mitigation
The economic activity manufactures low carbon products and technologies (and their key components) that demonstrate substantial life cycle GHG emission savings compared to the best performing alternative technology/product/solution available on the market.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
16 Sept 2020
Please find our feedback in the attached document.
Read full responseResponse to ReFuelEU Aviation - Sustainable Aviation Fuels
20 Apr 2020
We support the EU-SAF Blending Mandate with recommendations:
a) Should come into force after min. of 3 years to enable implementation of commercial SAF projects and to allow airlines, airports, and other stakeholders time to prepare.
b) To be effective, the cost of non-compliance should exceed and possibly be tied to the cost differential between SAF and conventional fuels.
c) The SAF blending mandate should persist for a minimum of 15 years in order to provide assurance for project financing.
We support the upward revision of the multiplier with recommendations:
d) It would be helpful for EU-wide guidance on transposition into national legislation, including interaction with other elements of RED II, such as double-counting of fuels from some feedstocks.
e) The multiplier should be set at a level that reflects the increased cost of SAF production relative to sustainable ground transport fuels.
We agree that new funding mechanisms are needed to expand SAF production and to close the price gap as production economics improve. EU funding mechanisms should:
f) Prioritize deployment of SAF pathways that expand the feedstock base, as oil-based feedstocks required for HEFA, currently at commercial scale in multiple locations, are limited.
g) Be reserved for facilities that produce SAF as a significant part of their product slate to ensure that consistency of production.
h) Reduce risk of investment in first commercial SAF technologies that are ready for commercial scale production. e.g capital grants and/or facilities for guaranteed, low-cost debt.
i) Support scale up and commercial demonstration of new SAF technology pathways so that they may develop the data needed to design and finance commercial-scale plants.
j) Support the price gap between SAF and fossil jet fuel as SAF comes down the price curve. One mechanism could be a feed-in tariff where producers (or buyers) get a set contribution to cover (part of) the additional costs of SAF relative to fossil jet. This should be available for an extended period to provide predictable economics for SAF projects.
k) Support build out of infrastructure needed for expanded SAF utilization.
The ‘State Aid rules for environmental protection and energy’ only lasts until the end of 2020 and a revised version should allow governmental and/ or EU support for the development of the EU SAF industry in parallel with a policy incentive (such as a blend mandate). These rules should not limit the amount of support given to SAF projects by the governments/ EU.
We agree that it is appropriate to establish priorities for both funding and feedstocks, including:
l) Funding of SAF pathways that diversify the feedstock pool and facilities producing SAF as a significant fraction of total output.
m) Production of new SAF feedstocks and collection of waste feedstocks to ensure that there is sufficient supply.
n) Feedstock is the largest single cost associated with SAF production so feedstock prioritization and financial support for SAF production could be met with a financial incentive for purpose-grown and waste feedstocks that are sold for SAF production.
Common SAF definition and reporting requirements will ensure a consistent and complete monitoring of the SAF production and use in the EU. Harmonization with CORSIA could minimize the burden on producers and end users.
We recommend clear sustainability guidelines that leverage mechanisms for certification that have been previously applied to road transport fuels:
o) SAF policies should promote diversification of pathways and feedstocks. Priority should be given to pathways using waste and residue feedstocks, including agricultural and forestry wastes, unrecyclable municipal wastes, and waste industrial process gases.
p) Holistic sustainability certification schemes, including environmental, social, economic impacts should be consulted in developing EU SAF policies and their principles incorporated into financing decisions.
Read full responseMeeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)
28 Jan 2015 · Presentation related to energy topics
Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)
27 Jan 2015 · Introductory meeting
Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)
26 Jan 2015 · Energy Policy
Meeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella)
26 Jan 2015 · Gas Fermentation technology