ESWET reply to the European Commission consultation on the proposed Delegated Act & Annex on GHG savings of low carbon fuels

ESWET welcomes the opportunity to provide feedback to the European Commission on the proposed Delegated Act (DA) and Annex concerning greenhouse gas (GHG) emission savings for low carbon fuels.

by ESWET

However, we are concerned that certain elements of the Act and Annex may overlook valuable low carbon energy sources, such as hydrogen produced from WtE processes and fuels derived from non-recyclable waste. This could hinder their development and integration, limiting the potential growth of these technologies from the start.

ESWET’s main points of concern:
1) Prioritising Carbon Capture and Utilisation (CCU) for fuel production from Waste-to-Energy (WtE) can often be a more practical solution for emissions reduction compared to Carbon Capture and Storage (CCS), thus the legislation should enable CCU from WtE
2) Clarification needed on inclusion of biogenic CO₂ from waste incineration under point 10(c)
3) Clarification needed on GHG calculation methodology and waste feedstock in low carbon fuel production
4) The sunset clause in point 10(a) of the Annex on deducting captured fossil carbon is very restrictive for hard-to-abate sectors like WtE
5) Point 10 (f) of the Annex should be interpreted in a way that includes captured fossil emissions from WtE facilities as eligible for emissions deduction
6) Clarity and consistency in EU legislation are imperative
7) E ex-use should consider explicitly landfill diversion, including that of plastic waste

8) Emissions from processing (e p) should consider unavoidable emissions from non recyclable plastic waste in WtE plants

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published: ESWET, 10|2024
Keywords: Energy Recovery, Pollution Control, Policy Tax Instruments, Sustainability, Climate, Mixed Waste, EU