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Stockholm Exergi

SE

Stockholm Exergi är ett lokalt energibolag som producerar fjärrvärme och el, samt slutbehandlar restavfall genom förbränning med energiåtervinning.

Lobbying Activity

Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

21 Dec 2023 · Presentation of the Stockholm Exergi's BECCS project

Meeting with Emma Wiesner (Member of the European Parliament)

17 Nov 2023 · Platsbesök

Response to Environmental claims based on environmental footprint methods

19 Jul 2023

Stockholm Exergi has submitted a response to the invitation to provide comments on the draft EU Green Claims Directive. The full response is provided as a public PDF-document, also available at https://beccs.se/about-beccs-stockholm/documents/. In the response, we propose Ten Principles for Claiming and Accounting of Net-zero and Permanent Negative Emissions (PNEs). The ten principles are: 1. For a corporation to be able to claim to be Net-zero, only PNEs can be used to neutralize hard-to-abate emissions in its Scopes 1 to 3. 2. In case a corporation wishes to claim to be Net-zero before all unabated emissions in its value chain have reached the residual level, the corporation must, in addition to neutralizing the emissions with PNEs, be committed to and deliver on an emission reduction trajectory in line with the Paris Agreement. Only as long as the corporation stays on the trajectory can it maintain its Net-zero claim. 3. In case a corporation wishes to offer Net-zero products, it must use PNEs to neutralize all emissions in the products value chain, including down-stream Scope 3 emissions from the usage of the product (notably emissions resulting from end-users consumption of the product and the products end-of-life treatment). In addition, the corporation as such must be committed to and deliver on an emission reduction trajectory in line with the Paris Agreement. Only as long as the corporation stays on the trajectory can it continue to sell products branded as Net-zero. 4. Any claim and accounting of a PNE must be accompanied by an audited confirmation that the corresponding certificate has been retired. 5. PNEs used for a claim of being Net-zero must be net of value chain emissions resulting from the project, which need to be further defined by certification methodologies. Consequently, while all PNEs should receive a certificate, to sell PNEs for Net-zero purposes, a portion of the issued certificates will have to be retired as defined by the methodology. 6. PNEs that have been exposed to reversals (i.e., release of CO2 from storage sites) shall be addressed by a compensation mechanism, like the ETS requirement to acquire EUAs for CO2 emitted from geological storage sites. 7. Just as is the case for an emission reduction, a claim and accounting of a PNE in the corporate system naturally also appears in the national claiming and accounting system. Accounting and claiming of a PNE within the two respective systems must only take place once per system. 8. Upon confirmation of permanent storage of 1 tonne of removed CO2, two certificates should be issued as twins, one for the corporate system (to the project owner) and one for the system of nations (to the host nation). 9. The certificates of the two systems should be stored in a common registry structure such that the twin certificates can be traced and tracked within the respective systems as well as between the two systems, for avoidance of double counting between nations or between corporations, and for maximum transparency. 10. Trade in the certificates should only be allowed to take place within the two respective systems, but not between the systems. In other words, corporates trade in the certificates issued for the corporate system and nations trade in the certificates issued for the system of nations. If a nation seeks to acquire PNEs directly from a project owner, it would, in addition to reaching a commercial agreement with the project owner, have to reach an agreement with the host nation to transfer the host nation certificate to the acquiring nation (in effect, this is a transfer of an ITMO from the host country to the purchasing country, and an associated Corresponding Adjustment by the host country would take place).
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Meeting with Heléne Fritzon (Member of the European Parliament)

15 Jun 2023 · Möte med Stockholm Exergi (APA-level)

Meeting with Erik Bergkvist (Member of the European Parliament)

15 Mar 2023 · Möte

Meeting with Pär Holmgren (Member of the European Parliament)

20 Feb 2023 · Study Visit: Stockholm Exergi

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

16 Nov 2022 · Meeting with Stockholm Exergi on Renewable Energy Directive

Response to Regulation on REPowerEU chapters

13 Jul 2022

A sustainable bioeconomy is inevitable if the goals of the Paris agreement are to be achieved. According to IPCC scenarios, biomass will replace fossil fuels and raw materials, but also provides the opportunity for permanent removals through BECCS. Stockholm Exergi is producing heat and electricity from forestry residues. Most of these residues arise as a consequence of other value chains, regardless of whether they are used for energy purposes or not. Thus the biomass is a secondary resource. EU must recognise and support bioenergy as a tool to make the Union independent on imported fossil fuels. Sweden has shown that it is possible for EU Member States to abolish the use of fossil fuels for electricity and heat production. In Stockholm, Stockholm Exergi operates the district heating system. In the 1970th, the district heating production in Stockholm was completely based on fossil fuels. Today, Stockholm has a nearly fossil fuel free heating system, which is also treating waste from the region and producing electricity with CHP in the central parts of the city. The power grid in the Stockholm region has a limited capacity. Stockholm Exergi´s CHP plants that are located in the central parts of the city are crucial for managing this problem. The solid biomass used in Stockholm is residuals derived from forestry and forestry industry, in line with sustainability criteria in the Renewable Energy Directive and recommendations made by the Joint Research Centre. As such, this energy source bring climate benefits without risking ecological values. This is a robust system with high security of supply, it is independent of imported fossil fuels from Russia. Yet, the ongoing adaptation of the Fit For 55 legislation risk putting a halt to this energy source. We urge co-legislators to ensure that sustainable use of sustainable biomass can contribute to the decarbonisation of European heating and electricity systems in the future as well. This is also crucial in order to ensure the viability of Bioenergy with Carbon Capture and Storage (BECCS), through which Stockholm Exergi can permanently remove 0.8 million ton of biogenic carbon dioxide annually – a project that the European Commission has supported via the Innovation Fund. We also suggest that final treatment of well-sorted waste through incineration and high level of energy recovery in combination with CCS/CCUS should be part of the RePowerEU-program as well as the EU's taxonomy, since it represents a significant and local energy source that would otherwise be lost.
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Meeting with Ville Niinistö (Member of the European Parliament, Rapporteur)

16 Mar 2022 · LULUCF (staff level)

Meeting with Pär Holmgren (Member of the European Parliament, Shadow rapporteur for opinion)

7 Feb 2022 · Effort Sharing (staff level)

Meeting with Jakop G. Dalunde (Member of the European Parliament)

3 Jan 2022 · Study Visit: Stockholm Exergi

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Stockholm Exergi believes that it is far too early to start an adjustment of the sustainability criteria in REDII. Any adjustment must be based on learnings from the ongoing implementation of the current REDII. Bioenergy is the leading energy source in Sweden. Bioheat today accounts for more than half of all space heating in the housing and service sectors, and biopower is today, after nuclear- , hydro- and wind power, the fourth largest source of electricity. Bioenergy replace fossil fuels (such as coal, natural gas and oil) which are the main cause of climate change. In addition, most IPCC scenarios based on ambitious climate targets require techniques to sequester carbon dioxide from the atmosphere. Stockholm Exergi aims to by 2025 introduce Bio-CCS technology in order to in large scale produce permanent technical negative emissions, based on already existing use of residuals from sustainable forestry. The use of sustainable bioenergy in Bio-CCS systems will ensure a major climate benefit also in a future when fossil energy no longer represents the realistic alternative. Researchers, expert organizations and Sweden's largest environmental organizations believe that forest bioenergy is needed for Sweden to achieve its climate goals. Using forest bioenergy is a resource-efficient way of generating energy. The biomass itself consists almost exclusively of residues, such as branches and tops, as well as sawdust, which would have become atmospheric carbon dioxide within time periods relevant to the climate goals if left in the forest. It is biomass of the type found in the sustainable quadrant of the EU JRC's matrix published 2021 (Camia et. al.; The use of woody biomass for energy production in the EU; JRC; 2021). The volume of biomass in Swedish forests has increased in recent decades, despite the fact that we have also increased the use of bioenergy. The carbon stock is growing and forestry thus represents a significant carbon sink, close to 40 million tons carbon dioxide annually in Sweden, even if the biomass output is considered as an emission of carbon dioxide according to LULUCF-regulation. Scenarios indicate that if forest management continues approximately as today, the carbon stock will continue to increase. The environmental goals must at the same time be achieved. Ecologically valuable areas need to be protected and forestry methods are today constantly being developed for increased ecological consideration. The most significant impact on biodiversity derives from forestry itself, especially the final felling, and it is done almost exclusively to produce products more valuable than bioenergy. The extraction of left-over tops and branches can take place in a way that does not increase the impact on biodiversity. Among other things, REDII aims to ensure that bioenergy does not conflict with biodiversity. We at Stockholm Exergi have recently started the work of implementing and fulfilling the new REDII sustainability regulations. We expect that many valuable experiences will be learned. A revision of the regulations should, in order to create value, be based on lessons learned from the present implementation of REDII. The residual products in the form of tops and branches account for approximately just 1 percent of the forest's total value chain. The market valuation of forest material in itself entails a resource-efficient use of biomass. The district heating sector's demand is limited only to low-value residual products that would arise regardless of the demand for district heating. With a correct pricing of greenhouse gas emissions from industry, transport and the construction sector, and with a correct valuation of negative emissions, both technical and natural removals, the market's willingness to pay for biomass will also in the future guide more effectively than any detailed regulation could achieve.
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Response to Updating the EU Emissions Trading System

7 Nov 2021

Make Negative emissions an explicit part of Fit for 55 already now With the urgency to build a completely new industry for negative emissions where the commitment of governments to engage in this task must be ensured without delay, negative emissions should already now become part of the Fit for 55 package. By 2025 at the latest, negative emissions should be eligible for the achievement of set targets and the necessary procedures for certification, measurement, reporting and verification as well as required registries be in place. According to Stockholm Exergi, the contribution by technical removals should be enshrined in the ESR domain as a separate post, first as optional and later supported by a compliance regime. To avoid unintended consequences of such a change, a maximum limit of the tonnage or percentage of emissions that should be allowed to be addressed with negative emissions could be explicitly laid out per member state. With a successful build-up of the initial industry, Stockholm Exergi believes that a compliance market for permanent carbon removal (BECCS and DACCS) should be introduced with the triple purpose of driving volume, off-loading taxpayers and ensuring that climate targets can be met. This should be mature to launch after 2030. If, when and how such a compliance market should be linked to the ETS will depend on whether the integrity of the ETS’ emission reduction path can be protected. At some point the marginal abatement cost will be so high that it will be desirable to see a convergence between the ETS and a compliance scheme for permanent removal. Other removal methods cannot be considered in the same way due to their lack of permanence. Bringing waste treatment services (WtE) into the picture Increasing ambitions for how the Union manages the waste sector can unlock multiple key climate and resource challenges of the EU, and play a central role in a sustainable carbon cycle. First, we need to increase circularity. To increase circularity, producers, households and corporations must become aware of the climate impact of waste. Today’s system of statistical climate reporting (based on the 2006 IPCC Guidelines) works against a circular economy. Since today’s system allocates the emissions of the waste treatment service with the incinerator if the service recovers the excess heat, households and corporations are rarely including the direct climate impact of their waste generation in their CO2 accounting. Neither do nations. As a consequence, many believe that the heat provided by the district heating network is the source of the problem. Ironically, if the waste treatment service was provided without heat recovery, the reporting rules would allocate the emission with the households and companies. This situation not only works against a circular economy, it also works against the EU ambition to promote district heating and heat recovery. The Commission should, thus, bring the matter before the next revision/adaptation of the 2006 IPCC Guidelines. Such a change should also be supported by increased focus on sorting solutions and systems to minimize waste and maximize circularity. Second, by prohibiting landfill of incinerable waste, Europe could both eliminate the potent and “residual” emissions from methane and reduce the need of negative emissions. At least 80% of the waste currently still landfilled can be redirected into circular systems. With thermal waste treatment of remaining reject with about 100 TWh additional energy recovery, the EU also have the opportunity to sustainably harvest and circulate more carbon. The emissions of a typical WtE plant will have a biogenic content of 40-60%. By including the fossil emissions part of WtE in the ETS, EU would both drive CCS of what will be among the largest point sources of fossil CO2 as well as gain additional access to biogenic CO2 for usage or storage. Stockholm Exergi believes that such a regime should be in place between 2030 and 2035.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

7 Nov 2021

Make Negative emissions an explicit part of Fit for 55 already now With the urgency to build a completely new industry for negative emissions where the commitment of governments to engage in this task must be ensured without delay, negative emissions should already now become part of the Fit for 55 package. By 2025 at the latest, negative emissions should be eligible for the achievement of set targets and the necessary procedures for certification, measurement, reporting and verification as well as required registries be in place. According to Stockholm Exergi, the contribution by technical removals should be enshrined in the ESR domain as a separate post, first as optional and later supported by a compliance regime. To avoid unintended consequences of such a change, a maximum limit of the tonnage or percentage of emissions that should be allowed to be addressed with negative emissions could be explicitly laid out per member state. With a successful build-up of the initial industry, Stockholm Exergi believes that a compliance market for permanent carbon removal (BECCS and DACCS) should be introduced with the triple purpose of driving volume, off-loading taxpayers and ensuring that climate targets can be met. This should be mature to launch after 2030. If, when and how such a compliance market should be linked to the ETS will depend on whether the integrity of the ETS’ emission reduction path can be protected. At some point the marginal abatement cost will be so high that it will be desirable to see a convergence between the ETS and a compliance scheme for permanent removal. Other removal methods cannot be considered in the same way due to their lack of permanence. Bringing waste treatment services (WtE) into the picture Increasing ambitions for how the Union manages the waste sector can unlock multiple key climate and resource challenges of the EU, and play a central role in a sustainable carbon cycle. First, we need to increase circularity. To increase circularity, producers, households and corporations must become aware of the climate impact of waste. Today’s system of statistical climate reporting (based on the 2006 IPCC Guidelines) works against a circular economy. Since today’s system allocates the emissions of the waste treatment service with the incinerator if the service recovers the excess heat, households and corporations are rarely including the direct climate impact of their waste generation in their CO2 accounting. Neither do nations. As a consequence, many believe that the heat provided by the district heating network is the source of the problem. Ironically, if the waste treatment service was provided without heat recovery, the reporting rules would allocate the emission with the households and companies. This situation not only works against a circular economy, it also works against the EU ambition to promote district heating and heat recovery. The Commission should, thus, bring the matter before the next revision/adaptation of the 2006 IPCC Guidelines. Such a change should also be supported by increased focus on sorting solutions and systems to minimize waste and maximize circularity. Second, by prohibiting landfill of incinerable waste, Europe could both eliminate the potent and “residual” emissions from methane and reduce the need of negative emissions. At least 80% of the waste currently still landfilled can be redirected into circular systems. With thermal waste treatment of remaining reject with about 100 TWh additional energy recovery, the EU also have the opportunity to sustainably harvest and circulate more carbon. The emissions of a typical WtE plant will have a biogenic content of 40-60%. By including the fossil emissions part of WtE in the ETS, EU would both drive CCS of what will be among the largest point sources of fossil CO2 as well as gain additional access to biogenic CO2 for usage or storage. Stockholm Exergi believes that such a regime should be in place between 2030 and 2035.
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Response to Land use, land use change and forestry – review of EU rules

7 Nov 2021

Make Negative emissions an explicit part of Fit for 55 already now With the urgency to build a completely new industry for negative emissions where the commitment of governments to engage in this task must be ensured without delay, negative emissions should already now become part of the Fit for 55 package. By 2025 at the latest, negative emissions should be eligible for the achievement of set targets and the necessary procedures for certification, measurement, reporting and verification as well as required registries be in place. According to Stockholm Exergi, the contribution by technical removals should be enshrined in the ESR domain as a separate post, first as optional and later supported by a compliance regime. To avoid unintended consequences of such a change, a maximum limit of the tonnage or percentage of emissions that should be allowed to be addressed with negative emissions could be explicitly laid out per member state. With a successful build-up of the initial industry, Stockholm Exergi believes that a compliance market for permanent carbon removal (BECCS and DACCS) should be introduced with the triple purpose of driving volume, off-loading taxpayers and ensuring that climate targets can be met. This should be mature to launch after 2030. If, when and how such a compliance market should be linked to the ETS will depend on whether the integrity of the ETS’ emission reduction path can be protected. At some point the marginal abatement cost will be so high that it will be desirable to see a convergence between the ETS and a compliance scheme for permanent removal. Other removal methods cannot be considered in the same way due to their lack of permanence. Bringing waste treatment services (WtE) into the picture Increasing ambitions for how the Union manages the waste sector can unlock multiple key climate and resource challenges of the EU, and play a central role in a sustainable carbon cycle. First, we need to increase circularity. To increase circularity, producers, households and corporations must become aware of the climate impact of waste. Today’s system of statistical climate reporting (based on the 2006 IPCC Guidelines) works against a circular economy. Since today’s system allocates the emissions of the waste treatment service with the incinerator if the service recovers the excess heat, households and corporations are rarely including the direct climate impact of their waste generation in their CO2 accounting. Neither do nations. As a consequence, many believe that the heat provided by the district heating network is the source of the problem. Ironically, if the waste treatment service was provided without heat recovery, the reporting rules would allocate the emission with the households and companies. This situation not only works against a circular economy, it also works against the EU ambition to promote district heating and heat recovery. The Commission should, thus, bring the matter before the next revision/adaptation of the 2006 IPCC Guidelines. Such a change should also be supported by increased focus on sorting solutions and systems to minimize waste and maximize circularity. Second, by prohibiting landfill of incinerable waste, Europe could both eliminate the potent and “residual” emissions from methane and reduce the need of negative emissions. At least 80% of the waste currently still landfilled can be redirected into circular systems. With thermal waste treatment of remaining reject with about 100 TWh additional energy recovery, the EU also have the opportunity to sustainably harvest and circulate more carbon. The emissions of a typical WtE plant will have a biogenic content of 40-60%. By including the fossil emissions part of WtE in the ETS, EU would both drive CCS of what will be among the largest point sources of fossil CO2 as well as gain additional access to biogenic CO2 for usage or storage. Stockholm Exergi believes that such a regime should be in place between 2030 and 2035.
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Response to Restoring sustainable carbon cycles

4 Oct 2021

Stockholm Exergi (SE) 2021-10-04 It takes a generation to build a new industry – we must start now Stockholm Exergi welcomes the Commission’s ambition to accelerate the development of technological and nature-based carbon storage and usage solutions. It wishes to emphasize that it is critical to start building the necessary infrastructure for a negative emissions industry immediately – it takes a generation to build an efficient industry. Actors like ourselves are ready to invest in innovative solutions if the right incentives and a stable structure are in place. Make Negative emissions an explicit part of Fit for 55 already now To ensure that Member States engage in the urgent task of building a negative emissions industry, negative emissions should already now become part of Fit for 55. The first step is to ensure that procedures for certification, measurement, reporting and verification, as well as required registries, are in place at latest by 2025. To avoid unintended consequences, a maximum limit of emissions that can be off-set by negative emissions should be specified on Member State level, symmetrical with the 225 mtonnes limitation in the European Climate Law (2021/1119). The contribution by technical removals should be enshrined in the LULUCF or ESR instruments, depending on the type of removal (BECCS and DACCS, respectively). It is crucial that the system set-up provides incentives for both nature-based and technical removals. While the latter might take more time to develop, both are considered necessary to reach climate neutrality and the 1,5°C target, and a delay in development of technical removals might prevent the EU from fulfilling its ambitions. On the question of mitigation hierarchy, while usage of fossil CO₂ is a risky path as it may delay the phase out of fossil fuels, the balance between biogenic usage (zero emissions with possible substitution effect) and storage (absolute physical removal) is initially best left to the market to work out based on price signals from users and off-takers of negative emission rights, potentially both governments and corporations. Concepts of CRCs Not all tonnes are equal. A most fundamental contribution by the EU should be to define a common reference framework for how the LCA emissions of different removal methods are calculated. While undoubtedly difficult, a system for qualifying the permanence of different removal methods/technologies is a prerequisite both for matching the climate challenge with adequate instruments as well as allowing for trade in CRCs and/or ITMOs. Stockholm Exergi sees a clear and significant risk for confusion on the market, and greenwashing, unless a robust nomenclature is established. It is thus essential that the term ”removal” is reserved for methods that reduce the absolute, physical concentration of CO₂ in the atmosphere (not a counterfactual avoidance or usage of fossil CO₂). For temporary removal of biogenic CO₂ or through direct air capture for the purpose of CCU, the CRC needs to be qualified to maintain the distinction between removal and usage. The EU should be a leader by both establishing trade in mitigation outcomes within the Union and promoting a trading platform on a global level. To leverage the net-zero ambitions of private corporations, the EU should establish a system where the voluntary carbon market can help drive climate mitigation through the acquisition of off-set certificates tied to the application of negative emission technologies. With proper definitions and a structured approach where corporate off-set certificates and government-defined mitigation outcomes are managed in public and transparent registers, the contribution by the voluntary market could be maximized while environmental integrity is maintained. In such a set-up, corporate off-set certificates would co-exist with government-held mitigation outcomes that could be internationally transferred within the EU or to other NDCs.
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