Ref. Ares(2022)6187195 - 07/09/2022
To ensure consistency between the steps included in the calculation of the GHG emission and the reference to
the fossil-based value proposed for the GHG savings estimate. Therefore,
an unique fossil fuel comparator equal
to 94 g CO2eq/MJ for both
liquid and gaseous RFNBO and RCF is recommended.
To minimise methodological choices (e.g. source of information) in the RFNBO GHG savings calculations
especially for electricity and refer to the
most up-to-date information available and subject to the particularities
of each individual project. In the absence of reliable actual data, improvement factors are suggested to recognise
the improvement of the country specific electricity mix.
To consider
CO/CO2 feedstock derived from petroleum products as
rigid inputs for the purpose of the future
methodology when it is an
unavoidable and unintentional consequence of the production processes (e.g. fuel
gas) in industrial instal ations.
To use
energy or mass balance approach to allocate GHG emissions to multi-products (and to explicitly
avoid
economic al ocation).
To grant explicit
recognition of the
benefits from
previous/current fate or use of RFNBO/RCF feedstocks.
o To subtract emissions from the inputs’ existing use or fate from the GHG calculation of RFNBO/RCF.
o To include into the emissions from existing use or fate the CO2 equivalent of the carbon incorporated in
the chemical composition of the fuel or emitted during processing that was or would have otherwise
been emitted as CO2 into the atmosphere, with the exception of CO2 stemming from a source of fossil
fuel that is deliberately burnt for the specific purpose of producing CO2. The carbon incorporated in the
chemical composition of the fuel or emitted during processing also includes that from CO2 captured
from air and biogenic CO2.
o To ensure enough flexibility when recognising the specific source of electricity displaced when waste
materials are diverted from incineration with energy recovery.
o To recognise
landfil ing as incineration without energy recovery for the purpose of the GHG emission
calculation (accordingly with the
Innovation Fund methodology[1])
To
recognise the multi-feedstock nature of future fuel production units and
dif erentiate the GHG emissions
from the dif erent fractions, using energy al ocation as the main criteria to allocate process emissions as well a s
to determine the RFNBO and RCF fraction of the final fuel corresponding to each individual feedstock jointly
processed.
o Avoiding a single carbon intensity value for different mix of feedstocks is deemed essential to
incentivise both RFNBO and RCF production, even if jointly co-processed.
o To allocate GHG emissions associated with each input (viz. RFNBO, RCF and other fuels) to the
corresponding fraction / type of fuel, e.g. emissions associated with RCF feedstock to be allocated to
the RCF fraction, emissions associated with RFNBO (renewable electricity) to be allocated to the RFNBO
fraction, etc to have clear recognition in the context of future RED II(I) compliance.
Need to
ensure consistency with Circular Economy ef orts and taxonomy regarding the rule to allocate product
outputs and GHG emission calculation in the event of multiple co-products.
To provide an explicit mention that the electricity complying with the criteria set in Article 27 (3) of Directive
2018/2001 and the corresponding delegated act is considered as fully renewable and therefore its emissions a re
considered as zero.
From:
(FE) <>
Sent: Thursday, 9 December 2021 13:10
To: Hiesinger Stefanie
@ec.europa.eu>
Subject: RED II - RFNBO - DA article 27 Additionality - FuelsEurope view points
Subject: Delegated act on appropriated rules for the production of renewable hydrogen from
electricity for RFNBO (RED II – Article 27)
Attachment: FuelsEurope (EU Association refining industry)’s view on additionality criteria
Dear Ms. Hiesinger,
It is my pleasure to contact you in my capacity of Policy Executive in
FuelsEurope, the European
Association representing the refining industry, with regard to the
delegating act on additionality for
the production of RFNBO (
Renewable Fuels of Non-Biological Origin) which we believe that your
Cabinet may receive and be able to contribute to in the very close future after the
Interservice
consultation, based on our understanding of the foreseen publication of the Das as mentioned in
article 27 of RED-II.
Our Association strongly supports the EU objective of net climate neutrality in 2050 and the circular
economy, and stands ready to support policy makers to reach such goals. The refining industry is
[1] https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/innovfund/wp-cal /call-annex_c_innovfund-lsc-2020-two-
stage_en.pdf
actual y transforming and sustainable
Low Carbon Liquid Fuels, including both RFNBOs and RCFs, are
the centrepiece of this transition. We foresee progressively phasing out crude oil towards multiple
sustainable feedstocks and technology pathways contributing to reduce GHG emissions at both our
sites and across the whole transport sector. We describe this strategy in our
Vision 2050 and
CleanFuelsForAl publications.
In this context, we warmly welcome the initiative of the EU COM to propose a detailed methodology
with the required criteria to provide a stable framework to rule the production of these RFNBO/RCF
in the close future. In this regard, we would like:
- To express our wil ingness to help, as/if you deemed it appropriate, bringing forward the
view of the refining industry as a key actor in this field
- To share with you some concerns regarding key aspects of the
delegated act on the
appropriated rules for the production of renewable hydrogen for electricity as we believe
that, at this early stage of development, too restrictive measures on renewable electricity
sourcing could real y hinder the potential development and deployment of this type of low
carbon fuels which are not at commercial scale today and for which a
flexible access to
renewable electricity would be essential to make them a reality at European level.
Therefore, for your kind consideration, I am pleased to share with you the summary of our main
recommendations here below (complemented by further details in the document attached):
1. The term renewable hydrogen should not be limited to hydrogen derived from renewable
energy sources other than biomass
Therefore, we would suggest the introduction of term “
renewable electrolytic hydrogen” in
the delegated act.
2. The delegated act should not impose renewable electricity generation assets to be
unsubsidized in order to qualify as additional
3. We understand that
time matching of renewable electricity production with the use of it to
produce renewable electrolytic hydrogen is required. We propose to consider a
phased
approach with a
broader enough time span of at least one month at the beginning to
match renewable electricity generation and the use of it to make renewable electrolytic
hydrogen.
4. The
geographical sourcing for the use of renewable electricity to make renewable
electrolytic hydrogen should be the
Union.
We would strongly support that at least initial y a wide scope of geographical sourcing, and
no limitation to a bidding zone or neighbouring bidding zones, would be needed to support
the case for the new production capacity needed at European level.
5. To consider the extension of the term Power Purchase Agreements (PPAs) to Power
Supply Agreements (PSA)
That would allow to increase the flexibility in using several sources of renewable electricity
and as such contribute to the reduction of the cost of making renewable electrolytic
hydrogen
Thank you in advance for your attention and contribution to develop the policy framework of these
important low carbon fuels for the refining industry.
We remain at your disposal for any questions or further details that you may deem useful.
Best regards,
