Consultation Response – Smart Sector Integration – June 2020

In response of the EC consultation on a Strategy on Smart Sector Integration , Bellona Europa has shared its feedback on 8th of June. Here we focus on renewable fuels and gases and the use of waste as a energy sources.

Our main points:

  • To ensure that smart sector integration actions actually contribute to emission reductions, Bellona Europa recommends the use of four screening criteria and their respective metrics for the initial climate evaluation of Smart Sector Integration actions.
  • Efficient and ‘circular’ use of resources must result in a direct decrease of carbon flows to the atmosphere, particularly fossil ones. Some stakeholder using 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. In this regards we recommend that 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.
  • Bellona Europa underlines the need of  a cradle-to-grave LCA that could  take into account both the fossil origin of the ‘waste’ and the emissions caused by the final combustion or disposal.
  • The European Commission might overhestimate the potential of smart sector integration as a climate change mitigation measure, instead it should focus on real and actual measures in both sectors because it (Smart Sector Integration) is not going to bring an enormous amount of reductions. SSI should be in places where there is additional renewable power sectors that cannot be used.

For further reading, find here our report on plastic to fuels.

Find the consultation response here as it follows: