FuelsEurope Statement on Delegated act on renewable liquid and gaseous fuels of non-biological origin (RFNBO) covering their use as final fuel or as intermediate
By 31 December 2021, the Commission has to develop a methodology to assess the greenhouse gas savings (GHG) from RFNBO. This delegated act will need to consider that:
Credits for avoided emissions are not given for CO2 capture which has already received an emission credit under other provisions of law.
A framework on additionally in the transport sector consists of different options with a view to determining the baseline of Member States and measuring additionally.
The above is intended to be achieved by the development of two delegated acts:
- One covering the methodology to calculate the GHG savings of the RFNBO;
- One dealing with the additionally requirements including elements like grid connectivity, RES-E use and proof and any other appropriate criteria.
FuelsEurope supports the development of the delegated act on the methodology to assess the GHG savings from RFNBOs.
However, we would like to call for a methodology that is not restrictive compared to other incentives provided for alternative energies and fuels.
We want to highlight that RFNBOs need already to comply with a 70% GHG saving threshold, which was set before a clear methodology on how to calculate this is to be developed, whereas the GHG savings threshold for biofuels is 65% as of 2021.
Additionally, the direct use of electricity in road transport is incentivized with a multiplier of four and rail transport with a multiplier of 1.5, whereas the use of renewable electricity to produce RFNBOs is already severely restricted by the RED II requirements and might be even further restricted based on the application of “any other additional criteria”.
Therefore, we would like to call on:
- To maintain the possibility of using grid-electricity as provided by article 27, meaning that the renewable electricity content is based on the previous 2-year average electricity from renewable sources without any further restrictions.
- The evidence of the renewability of the electricity can be proofed via Guarantees of Origin (GoOs) or Power Purchase Agreements (PPAs).
- To limit the concept of additionality to the need to provide evidence that the fuel producer is adding to the renewable electricity deployment or the financing of renewable electricity. The last should include the possibility of financing through the establishment of long-term renewable electricity purchase contracts. The temporal and geographical correlation between the electricity production unit and the producer of the RFNBO – as mentioned in the directive - should not be interpreted as:
- The need to have an instantaneous match between the production of and the use of renewable electricity, but instead a balanced approach over a broad enough time-span.
- The need to have a physical connection between the point of production of renewable electricity and the point where it is used to produce the This principle is already used currently for the existing renewable electricity market. We believe that there should not be any requirements for RFNBOs which are not applied to renewable electricity production and use in general such as direct use in road and rail transport.
- No discrimination of CO2/carbon sources should take place, hence direct air captured CO2 and CO2 from point sources should be treated equally by the to be developed Both technologies to capture CO2 ultimately lead to atmospheric CO2 level reduction or avoid further CO2 being emitted to the atmosphere. Over the longer term direct air capture might be considered as fully closing the loop to carbon-neutrality.
- FuelsEurope supports the work and the results proposed by JEC on the JEC WTW Study – version 5, associated with RFNBOs.
- FuelsEurope is of the opinion that the use of RFNBO (e.g. green-hydrogen) as intermediate product in the production of conventional fuels, should be taken into account based on the energy content of the used RFNBO.
- The use of green-hydrogen as intermediate RFNBO in the production of conventional fuels, should be accounted in the Member State of consumption of the final fuel since the obligation under the RED II for transport is on the fuel supplier for the fuels he brings to the market.