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St1 Nordic Oy

St1

The vision of St1 is to be the leading producer and seller of CO2 aware energy.

Lobbying Activity

Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

10 Jun 2021 · Roundtable of the Clean Hydrogen Alliance: 3rd meeting of the co-chairs

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

St1 Nordic Oy welcomes the initiative to review the ESR regulation. As climate change is a global challenge. the solution should be designed in a flexible manner to avoid sub-optimization. The ongoing review of the ERS, ETS, and LULUCF should be conducted as a tightly interlinked and coherent manner, with an objective to create a cross-sectoral framework that enables Member States and obligated actors under the emission reduction legislation to do climate actions as cost efficiently as possible across Europe. After all, the ultimate goal of climate policy should be to support the implementation of the most cost-effective and impactful climate actions. The ongoing ESR review should be used as an opportunity for making a significant systemic change by exploring the possibility to shift regulatory mindset and framework from sector-driven system to flexible and integrated cross-sectoral system enabling tapping the potential of the most cost-efficient climate actions. Making a systemic change that would lead to real synergies requires coherent assessing of all relevant legislation. EU’s ability to fully exploit cross-sectoral cooperation and opportunities it entails will be a crucial factor in achieving climate ambitions, as the vast majority of actual measures are already in use or known. This is particularly true in some sectors, such as transportation. The scalability and pace of electric mobility and biofuels are well known and limited. On the other hand, an area, which is clearly lacking investments today, is the nature-based carbon sinks, in the LULUCF sector. Thus, the future regulatory framework should be focusing on accelerating and enabling synergies between the sectors. Mechanisms supporting cross-sectoral climate actions could enable significant and cost-efficient solutions, faster than today. At the moment the missing incentives and possibility to utilize climate actions across the sectors result in a situation where cost-efficient carbon reduction measures may be left undone as there is no demand for the measures as they are not produced in a way that is required in a specific sector with demand potential. We cannot afford not to use this potential. It has been stated in many reports and research, e.g. IPCC Special Report , that the current climate commitments and targets cannot be achieved by only focusing on emission reductions but also the potential of negative emissions should be tapped. In 2020 a ton of reduced CO2 achieved by using biofuels has been up to 430 EUR while an emission right in the ETS costs around 25 EUR. Making something completely emission-free is more expensive than trying to reach a realistic emission reduction in multiple domains. Expanding the coverage of ETS to other sectors (e.g. transportation), combined with a model where some of the emission obligations of the industry could be fulfilled by purchasing emission rights resulting from carbon sequestration projects done in other sectors, such as LULUCF. Allowing flexibilities and using the ETS as the key platform enabling that, should not be seen as a way to water out the climate targets. In contrary, it would be a vehicle for more ambitious target setting, and a faster and more effective tool to trigger the investments needed. If transport were to included in the ETS, the ESR might become redundant. Some of the sector specific targets do not have to be discarded, when there is need for such. On the contrary, they could and should be used to promote and accelerate desired solutions, which may not be economically or technically viable today, but hold great potential for the future. Some transport fuels, eg. Advanced Biofuels and Synthetic Fuels, will still require specific sub targets, to ensure their ramp up during 2020’ies. The final legislative design and sector structure should be designed so that measure could be deployed in a fast pace and cost-effective manner, without artificial hurdles created by too rigid legislation.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

St1 Nordic Oy welcomes the initiative of the Commission to review the ETS regulation. As climate change is a global challenge, also the proposed solution for solving it should be designed in a flexible manner to avoid sub-optimization. The ongoing review of the ETS and Effort Sharing Regulation (ESR) should be conducted as a tightly interlinked and coherent manner, with an objective to create a cross-sectoral framework that enables Member States and obligated actors under the emission reduction legislation to do climate actions as cost efficiently as possible across Europe. After all, the ultimate goal of climate policy should be to support the implementation of the most cost-effective and impactful climate actions. The ongoing ETS review should be used as an opportunity for making a significant systemic change by exploring the possibility to shift regulatory mindset and framework from sector-driven system to flexible and integrated cross-sectoral system enabling tapping the potential of the most cost-efficient climate actions. Making a systemic change that would lead to real synergies requires coherent assessing of all relevant legislation. EU’s ability to fully exploit cross-sectoral cooperation, and opportunities it entails, will be a crucial factor in achieving climate ambitions, as the vast majority of actual measures are already in use or known. This is particularly true in some sectors, such as transportation. The scalability and pace of electric mobility and biofuels are well known and limited. On the other hand, an area, which is clearly lacking investments today, is the nature-based carbon sinks, in the LULUCF sector. Thus, the future regulatory framework should be focusing on accelerating, or at least, enabling synergies between the sectors. Mechanisms supporting flexibility and cross-sectoral climate actions could enable significant and cost-efficient solutions at faster pace than today. At the moment the missing incentives and possibility to utilize climate actions across the sectors result in a situation where cost-efficient carbon reduction measures may be left undone as there is no demand for the measures as they are not produced in a way that is required in a specific sector with demand potential. We cannot afford not to use this potential. It has been stated in many reports and research, e.g. IPCC Special Report , that the current climate commitments and targets cannot be achieved by only focusing on emission reductions but also the potential of negative emissions should be tapped. In 2020 a ton of reduced CO2 achieved by using biofuels has been up to 430 EUR while an emission right in the ETS costs around 25 EUR. Making something completely emission-free is more expensive than trying to reach a realistic emission reduction in multiple domains. Expanding the coverage of ETS to other sectors (e.g. transportation), combined with a model where some of the emission obligations of the industry could be fulfilled by purchasing emission rights resulting from carbon sequestration projects done in other sectors, such as LULUCF. Allowing flexibilities and using the ETS as the key platform enabling that, should not be seen as a way to water out the climate targets. In contrary, it would be a vehicle for more ambitious target setting, and a faster and more effective tool to trigger the investments needed. Some of the sector specific targets do not have to be discarded, when there is need for such. On the contrary, they could and should be used to promote and accelerate desired solutions, which may not be economically or technically viable today, but hold great potential for the future. For example, some transport fuels, such as Advanced Biofuels and Synthetic Fuels, will still require specific sub targets, to ensure their ramp up during 2020’ies.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

St1 Nordic Oy welcomes the initiative to review LULUCF, with an aim to increase carbon sinks to 500 Mt CO2eq./a by 2050. Now,the sinks are declining. A key contributor to the negative trend is that activities related to carbon sequestration are currently not sufficiently rewarded. In EU policy framework, the EU trading of land-based carbon removals is currently limited to the Member State level. To turn the trend, a significant injection of capital towards creation ("choke capital") and maintenance of nature base carbon sinks is needed. LULUCF sector itself, or Agriculture or Forestry as integral parts of the sector, lack incentives to maintain the sinks. Necessary funding could come both from public (e.g. CAP, national afforestation legislations etc.) and private sources, eg. through Carbon Removal Credits (CRC) from other sectors. Most of the EU’s current emissions come from fuel combustion, of which most of the emissions are from the energy industries and transport. These sectors would have an inherent demand potential for using CRCs. Also, their sector specific mitigation costs, especially in all the transport sectors, would favor the use of CRCs as an additional tool for complying with sector specific targets The potential demand would be far greater than the potential of nature-based CRC supply. If the current carbon sink level of ca. 250 Mt CO2eq./a would be considered as a baseline, the targeted additional ca. 250 Mt CO2eq./a by 2050 would form the theoretically maximum potential supply of CRC. Comparing it with the GHG emissions from the EU27 in 2018 of 3,893 Mt CO2eq. that would have to be reduced close to zero by 2050, it’s evident that deep emission cuts inside each emitting sector would still be needed. Legislation would set the level eligible CRC supply, in relation to overall and sector specific GHG reduction targets, to optimize the ambition and risk level. Risk of watering out the sector specific emission reduction target, can be deemed low, and manageable. Also, a hybrid model combining public and private funding could be an interesting possibility, that would deserve a proper economic and legal evaluation in the light of preparing new EU legislation. As Commission states, the current framework is not fit for purpose. Dismantling the hard walls between sectors, and enabling companies to use nature-based CRCs, is the main principal decision to be made. Secondly, the use of CRCs should be linked directly to emitting sectors, and not via an aggregated level such as ESR. Eg., transport has a renewable energy target of 14% by 2030, which is likely be increased. Already today, obligated parties (eg. fuel suppliers using biofuels) must demonstrate their compliance through established mechanisms. Those mechanisms could relatively easily be modified to accommodate the use of CRCs, as well. ETS also has a proven and robust system to accommodate use of CRCs. A common upstream part of the CRC value chain does not exist yet. For example, the creation and validation, as well as Monitoring, Registration and Verification (MRV) for CRC is missing. Through creating a robust upstream structure, and by combining it with the existing downstream structures, the use of CRCs in the compliance market could be enabled in an effective manner. A coherent legislation is a key pre-requisite. There are legitimate key criterias, eg. additionality, permanence and carbon leakage, to be put in place. “A ton of CO2 is a ton of CO2”, is a non-negotiable principle for CRCs. It’s worth noticing that, in some other sectors the requirement is less stringent. For example, the minimum threshold for biofuels is 65% GHG reduction vs. fossil comparator. Or BEVs are considered zero emission vehicles, regardless of the electricity used. The example illustrates that, when applying the above principle, a ton of CO2 in the form of CRC can actually be more than a than a ton of CO2 in a form of avoided emission somewhere else.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

To maximize the impact and effectiveness of the emission mitigation measures, EU should move towards more technology neutral approach that looks Negative Emission Technologies and Processes (NETP) as complementing efforts to emission mitigation. Therefore, St1 calls for exploring the possibilities to open the boundaries and seek flexibilities between the different sectors. Minimum targets should be designed in a way, that they do not create a practical ceiling for RE solution at the same time. RED2, and any related regulation, should enable significant freedom of choice of solutions for Member States that go above the EU set minimum levels. Specifically, ensuring Member States to have a high level of freedom to allow flexibility between the sectors (ETS, Effort Sharing and LULUCF), would trigger cost effective climate measures that would benefit, not only the Climate, but also the Member States in question, and the entire EU. The use of Nature Based Carbon sinks should also be an eligible tool above the EU minimum levels. Any mandate or target should be set as a CO2 reduction target (or a carbon intensity target) based on Life Cycle emissions, instead of energy based or volumetric target. Any energy carrier, fulfilling the set sustainability criteria, should be eligible for fulfilling the target. That would drive towards more efficient solutions and overall benefit. The same principle should be applied in all mechanisms whenever possible under the RED2 regime, and beyond. Some transport fuels, such as Advanced Biofuels and Synthetic Fuels, will still require specific sub targets, to ensure their ramp up during 2020’ies. To increase the potential effectiveness, any waste and residue material that do not fit for use in the food or feed chain, should be recognized as sustainable feedstock for Advanced Biofuels production, combined with an upward revision of the subtarget for Advanced Biofuels. Such change, or any other change in the feedstock base, requires a comprehensive grandfathering of investments done in good faith, under the current regime. To capture the potential of so-called Synthetic Fuels (or Renewable Fuels of Non-Biological Origin), an initial phase tailormade support is essential to create a market, and to trigger the required investments. Clean Hydrogen, based on a robust LCA covering the entire value chain, the center piece of EU’s decarbonization strategy, whether as a key component for Synthetic Fuels, or as pure Hydrogen in gaseous form. Member States with undeveloped gas grids are more likely to deploy liquid Synthetic Fuels than gaseous Hydrogen. Therefore, any provisions related to the hydrogen value chain, should enable all energy carriers and applications in a fair and consistent manner. Any point source CO2 emission, whether of biological or fossil origin, should be treated equally in the LCA calculation rules of Synthetic Fuels. As long as, there will be CO2 point source emissions under the regime of ETS with allowed emissions, using CO2 of fossil origin as a component in Synthetic Fuels is from the climate perspective equally good as CO2 of biological origin. Guarantees of origin should be introduced and accepted in a harmonized way as way a of proving the renewability of electricity used in production of Synthetic Fuels and other Low Carbon Fuels, eg. Biofuels and Advanced Biofuels.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

St1 welcomes the EU’s Green Deal and supports the target to achieve climate neutrality in the EU by 2050. Even though the length, depth and the recovery profile of COVID19 caused reduction in the aviation activity level is not known yet, it is fair to assume that it will reach and surpass the pre-corona levels significantly, over the coming decades. Thus, the decarbonisation of the aviation sector will be a key element to achieve the overall 2050 target. As electrification of the aviation at scale, is not a feasible alternative prior 2050, and probably not after that either, Sustainable Aviation Fuels (SAF) is one important tool for decarbonising the industry. In addition to sectoral activities, cross-sector emission reductions and negative emissions, such as natural carbon sinks, will be needed to balance off the remaining aviation-based emissions. The design and trajectories of the SAF policies should realistically address the obstacles and bottlenecks in ramping up the production. (more detailed statement in the attachment)
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Meeting with Arto Virtanen (Cabinet of Commissioner Jutta Urpilainen)

12 Feb 2020 · Green deal

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Ørsted A/S and

7 Mar 2019 · Advanced biofuels

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

21 Nov 2017 · Energy investments

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen) and UPM-Kymmene Oyj

26 Oct 2016 · Energy Package

Meeting with Jyrki Katainen (Vice-President) and

25 Feb 2016 · Advanced biofuel industry in Europe

Meeting with Jyrki Katainen (Vice-President) and UPM-Kymmene Oyj and

25 Feb 2016 · Biofuels

Meeting with Carlos Moedas (Commissioner) and UPM-Kymmene Oyj and

25 Feb 2016 · Meeting with CEOs of European countries commited to the development of low carbon transport fuels

Meeting with Violeta Bulc (Commissioner) and

25 Feb 2016 · Meeting with Mr Anders Fogh Rasmussen and Advanced Biofuels CEOs

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc) and North European Oil Trade Oy

9 Jul 2015 · Meeting with North European Oil Trade Oy/St1 Biofuels Oy

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen) and UPM-Kymmene Oyj

12 May 2015 · Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

12 May 2015 · Circular Economy