EU Green Energy Transition should keep emission reductions at its core

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On Wednesday the 8th of July, the European Commission has adopted two strategies to transform Europe’s energy system: the Energy System Integration and the Clean Hydrogen strategies.

The EU Strategy for Energy System Integration is said to  provide the framework for the green energy transition, towards a more efficient and interconnected energy sector.

Bellona Europa welcomes this specific strategy and in particular its focus on the entirety of the energy system, including on the role of CO2 transport and storage. The Commission’s acknowledgement of the slowness at which uptake of CO2 storage currently takes place in the EU paves the way for urgently seeking to improve this process of key importance in a net-zero EU. We welcome the proposal for an annual European CCUS Forum to be convened and we look forward to being involved in this process.

An important element is the proposal for the development of a comprehensive terminology for renewable and low carbon fuels, a sphere where ambiguity on CO2 input and output has allowed a delay of available actions in favour of wishful thinking and creative future accounting. This provides a relevant example of how system integration could add complexity that undermines climate action.

If the goal of this strategy is to create “the pathway towards an effective, affordable and deep decarbonisation of the European economy in line with the Paris Agreement”, then smart sector integration actions should directly and as a priority contribute to emission reductions in line with a net zero by 2050 pathway. As we underlined in our joint policy briefing Recycled Carbon Fuels in the Renewable Energy Directive : getting both terminology and accounting right will be crucial.

Bellona Europa has recommended the use of screening criteria and their respective metrics for the initial climate evaluation of EU Smart Sector Integration actions. We stand by our proposal and would like to recall our recommendations for this strategy:

  • Efficient and ‘circular’ use of resources must result in a proved decrease of carbon flows to the atmosphere towards a net-zero calculation;
  • Emissions from waste should be accounted for, particularly if the waste is of fossil origin and the net carbon flows to the atmosphere are still increasing;
  • Selective life cycle assessment (LCA) (with narrow boundaries such as cradle-to-gate or gate-to-gate), allows for the CO2 emissions from the end-of-life phase of the product to be lost, giving the false impression that almost no GHGs will be emitted to the atmosphere – this has to be dealt with through honest accounting.
As mentioned in our Smart Sector Integration consultation response from June 2020, we continue to be concerned with the risk of the European Commission overestimating the potential of smart sector integration as a climate change mitigation measure in itself, when instead it should be used in places where there is additional renewable power sectors that cannot be used.
From that perspective, the strategy does complement well a clean hydrogen strategy. In our latest position paper on Clean Hydrogen Strategy, we have underlined the need for setting clear sustainability standards in order to deliver on net-zero. Sustainability criteria including most up to date data on carbon grid intensity is a basic requirement for clean hydrogen. We call for a realistic take on where we are to build the net-zero world of tomorrow, instead of using the net-zero accounting rules that overlook the CO2 intensity of the electricity used in the next decade to power up our hydrogen powered EU. Ignoring this risk management strategy could set us on a path to a not-so-clean, fossil fuel intensive, future.
We warn that unless emission reductions on a system level becomes the main driver behind those actions, smart sector integration will fail to guarantee and contribute to the net-zero climate promise of tomorrow.