T&E's consultation response to the Commission's methodology to determine the GHG emission savings of low-carbon fuels
According to the EU Commission, low-carbon fuels may play a role in the energy transition, particularly in the short and medium term, as they emit fewer emissions than existing fuels and support the uptake of renewable fuels.
The EU has a certification procedure in place to ensure that low-carbon fuels reduce emissions in practice.
This delegated act sets out the methodology to determine the GHG emission savings of low-carbon fuels, based on a life cycle assessment of the total GHG emissions of these fuels.
T&E recommends the following:
A more conservative default value for upstream methane emissions. The data used to underpin the default values should be shared and updated in light of the significant shifts in the mix of EU gas suppliers. The default values should reflect the higher level of fugitive methane emissions of suppliers gaining in importance (US in particular).
Midstream emissions from transporting the fossil gas feedstock must be taken into account. T&E asks for clarity whether and how the midstream emissions will be accounted for, as these can be significant - especially in the case of LNG.
The low-carbon fuels delegated act should use the GWP20 for fossil gas.
Fugitive hydrogen must be included in the low-carbon fuels GHG methodology. If not, hydrogen leakage must at least be part of the 2028 review.
The list of carbon sources should be consistent for RFNBOs and low-carbon fuels. Hence, the 2041 deadline for phasing out the eligibility of fossil carbon should be maintained. However, more incentives and support are needed to scale up non-biogenic sources of carbon, particularly Direct Air Capture (DAC), ahead of the 2041 phase-out date for fossil carbon.
To ensure climate neutrality, the European Commission should assess the merits of a higher GHG savings threshold for low-carbon fuels in its mid-2028 review as well as the principle of non-additionality of fossil gas production used to produce low-carbon fuels.
The production of RFNBOs and low-carbon hydrogen should not undermine or slow down the decarbonisation of the grid.
