NextChem - Maire Tecnimont Group
NextChem is the partner to accelerate your Energy Transition and reduce your impact on the environment, creating new products from renewable feedstock and entering new markets with a non-fossil footprint, giving a contribution to sustainable development.
ID: 699705744091-57
Lobbying Activity
17 Jun 2022
Nextchem provides the following comments:
1. Foreword n. 7
The provision seems to allow sustainable fuels to play a transitional role until complete electrification of transportation begins in 2035. This scenario, however, concerns only light road transport, while it is not possible for maritime, air, and nor heavy road transport. In these sectors even after 2035, decarbonization will be based on the use in endothermic engines of sustainable drop-in fuels. In fact, the RED2 reform proposal and the ReFuel Aviation Eu proposal introduce a specific sub-target for RFNBOs in transport, that is not a food/feed competitive fuels.
Since the Delegated Act, instead, has generic validity for all fuel types and all modes of transport, the single reference to the year 2035 is not understood.
Moreover, even regarding only light road transport, the provision equates the date after which endothermic-engine vehicles can no longer be placed on the market with the date after which such vehicles will no longer be allowed on the road. Actually, even after 2035, vehicles with endothermic engines (ICE) that have been purchased before then will still continue to be on the road, and they will need to be refueled with drop-in fuels.
For that matter, some synthetic fuels are produced from unrecyclable waste, thus enabling them to solve a waste and waste management problem and reduce landfilling.
Lastly, the 2035 deadline could be a disincentive for the aviation or shipping sustainable fuels sector, which is a market in its infancy. This is in contradiction to the very rationale of the norm, which is to regulate the spread of sustainable fuels.
2. Annex I, Part A, paragraph 1 last sentence.
The provision is interpreted to mean that in cases where the same process allows for fuels that have lower carbon intensity, in addition to RCFs and RFNBOs, this is not considered.
We do not understand the meaning of this norm, which appears to be discriminatory and risks prejudicing certain types of fuels or technologies that require a mass balance between multiple end products.
3. Annex I, Part A, paragraph 3 (a) and (b).
Two different calculation methodologies are mentioned that can be applied to determine the share of RFNBO and RCF in the event that the output of a single process is represented by both fuels.
One possible interpretation could be the following: since the processes leading to the production of RCF and RFNBOs could also have outputs other than the two aforementioned categories (i.e. advanced biofuels, fossil fuels), applying both one and the other criterion would allow for an accurate mass calculation. A single criterion could be applied to identify the quantity of both types of fuels only if they were the only process outcome, in which case having identified the quantity of one, it would be possible to finer the other by subtracting the difference. In processes with end products of third categories, the overlap of two criteria is necessary.
We request that the reason for the two criteria be explicitly mentioned.
4. Annex I, Part A, paragraph 12
It is not specified how far along the supply chain the calculation of emissions from waste (rigid input) is extended.
Considering the complexities of this assessment, it is opportune to consider only emissions produced during industrial-type treatment processes, thus excluding collection, sorting and selection processes, with mechanical-biological treatment operations included instead.
5. Carbon intensity of electricity.
It is proposed that national levels of the carbon intensity of electricity be periodically updated, considering the evolution of electricity production modes in individual states.
Read full responseMeeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)
9 Sept 2021 · CBAM green energy transition