Letter: Environmental safeguards needed for CCU fuels in the Renewable Energy Directive

In light of the trilogue on the RED II taking place in early May, Bellona has, together with Transport&Environment, Zero Waste Europe, Carbon Market Watch and Sandbag, sent a letter to the negotiators on the inclusion of Carbon Capture and Utilisation (CCU) fuels in the directive. The letter expresses our concern about the inclusion of a wide variety of Carbon Capture and Utilisation (CCU) fuels – we are therefore seeking robust environmental safeguards to protect the integrity of the EU’s climate and energy policy framework. The RED is intended to accelerate the growth of renewables and act to reduce emissions. As currently drafted the inclusion of CCU fuels risks undermining both these aims.

The letter expresses our concern about the inclusion of a wide variety of Carbon Capture and Utilisation (CCU) fuels. Therefore, we are seeking robust environmental safeguards to protect the integrity of the EU’s climate and energy policy framework. The RED is intended to accelerate the growth of renewables and act to reduce emissions. As currently drafted the inclusion of CCU fuels risks undermining both these aims.

We strongly support the European Parliament’s position on requiring one type of CCU fuels (renewable fuels of non-biological origin – RFNBOs) to use CO2 captured from the air as the carbon-based feedstock (Article 2, paragraph 2, point s). This amendment will help to protect the integrity of the EU Emissions Trading System by preventing ‘leakage’ of emissions from industrial sectors (under the ETS cap) to the transport sector.

We are also concerned about the proposed inclusion of Waste-Based and Recycled Carbon Fuels, and therefore believe that, as a minimum, robust standards for greenhouse gas emissions savings (at least 70%) should be required.

Under current proposals, the Renewable Energy Directive will fail to ensure additionality in terms of renewable electricity technologies installed to provide the energy input to electrofuel production. Without additional measures, we see a real risk that the renewable energy content of electrofuels will in effect be double-counted, undermining any potential environmental benefit of the fuels and reducing the ambition of the overall renewable target.

Irrespective of the type of CCU fuel, a full life cycle assessment should be a pre-requisite for any project seeking access to public funding, taking into account both the CO2 source and energy inputs, on a cradle-to-grave basis.