Eurelectric response to the public consultation on Certification of carbon removals – EU rules

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  • Eurelectric welcomes and supports the European Commission initiative to prepare an EU-wide and robust certification system for carbon removals in the near-term.
  • The ambition level of 5 MtCO2 industrial carbon removals by 2030, as suggested in the COM’s Sustainable Carbon Cycles communication, seems to be on the low side, bearing in mind both the current plans in the business community and the parallel target which the COM is proposing for carbon farming (42 Mt CO2 by 2030).
  • Carbon removals are indispensable for reaching the EU’s climate-neutrality goal for 2050 and the EU climate policy framework needs to be urgently reformed with a view to support this type of climate activities. However, while recognizing the need of carbon removal in industrial sector beyond 2030, the EU regulation should incentivize to pursue GHG abatement (e.g. through RES, electrification) when feasible, limiting carbon removal to those activities that can deliver negative emissions, or not be otherwise avoided in hard to abate sectors
  • A special focus is needed on technology-based carbon removals. These can be measured and verified more accurately than nature-based solutions, while also offering more high-quality and long-duration (permanent) removal of CO2 from the atmosphere . Consequently, The EU certification framework should allow different types or sub-categories of certificates to better reflect the diversity of carbon removal solutions and their characteristics and ensure market integrity.

Given the need to ensure that emissions removed from the atmosphere remain stored, The EU regulatory framework should also mandate multi-year monitoring plans at the outset of the certification procedure.

  • While the result of a carbon farming project naturally belong to the LULUCF sector, the result of an industrial carbon removal project is more reasonably counted against the national ESR targets. Further assessment is needed around the role of carbon removals and the associated credits in the EU ETS domain. When creating the certification system the Commission must ensure the integrity of the existing legal framework of the EU ETS and its rules for the monitoring and reporting of emission. This existing framework should provide the foundation for the certification of industrial carbon removals in the upcoming EU regulatory framework.
  • We support the establishment of a baseline; the EU certification framework should allow for a variety of baselines and additionality criteria to cater for different types of removals
  • Double counting or double claiming of the same carbon removal must always be avoided. Independent private entities should be in charge of the certification process, guided by strict public control.
  • The definition of RFNBO in the Directive on renewable sources does not specify the origin of carbon used in the process which leaves the opportunity to use fossil CO2 to produce e-methanol that can qualify as RFNBO. If the origin of carbon for the production of RFNBO were to be specified in future pieces of legislation, biogenic CO2 quantities can be limited and technologies for Direct Air Capture (DAC) of CO2 will not be available shortly at affordable costs. Regarding industrial CO2, ‘avoidable’ CO2 is emitted during the combustion of fossils needed for the energy input in the process and ‘unavoidable’ CO2 is intrinsically emitted by the process itself. As a result, the use of ’unavoidable’ emissions of CO2 should remain among possible options for industries and the e-methanol produced should be considered as RFNBO.
  • There is today a growing consensus regarding the need to develop at an industrial scale synthetic fuels in order to be able to reach our decarbonation goals (e.g targets of ReFuelEU Aviation proposal[1] with 2% of SAF in 2025 until 63 % in 2050). The challenges are important to develop viable and affordable industrial processes and therefore the use of unavoidable industrial CO2 seems the only realistic way to develop those routes in the short to medium term.
  • A certification system for carbon removals alone is not enough to promote this type of climate projects. New policy incentives need to be developed in parallel, which lead to an increased demand for these credits including support schemes and EU funds. And doing it only for the EU’s post-2030 legislative cycle, as suggested by the EU-Commission, will be insufficient.
  • Eurelectric supports the EU Green Deal Climate Target for 2030 and the Net Zero target for 2050. Eurelectric is a vocal supporter of the accelerated energy transition, leading the charge in decarbonisation and promoting cost-efficient decarbonisation & electrification across Europe. A key component to reach our targets are to create sustainable carbon cycles.

[1] Proposal for a regulation of the European Parliament and of the Council on ensuring a level playing field for sustainable air transport, July 2021.

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