Bellona Europa Consultation Response: Net Zero Industry Act

Bellona Europa welcomes the Net Zero Industry Act and provided an answer to the European Commission’s Consultation.

The NZIA aims to promote net zero technologies at climate relevant timelines, such as carbon capture and storage (CCS). The act also covers crucial aspects of a just transition, by highlighting the need for skills and creation of sustainable jobs for a net-zero future. The text also covers means of speeding up permitting. An area of concern identified by Bellona Europa is that faster permitting carries risks of blanket support for technologies which need robust regulatory frameworks. This is particularly the case for hydrogen. The inclusion of hydrogen must contain strict conditionality to ensure its production and use comes with an actual climate benefit. To ensure the NZIA delivers on its potential to further climate ambition, Bellona Europa suggest addressing and revising crucial parts of the text. Here are our key recommendations:

  • Keep exclusion of Enhanced Hydrocarbon Recovery (EHR) within storage injection capacity target. 
  • Update storage injection capacity target every 5 years in line with EU climate ambition and expected supply of CO2.
  • Update reports mentioned in article 17.1 every 5 years in line with NECPs to have current data on storage site availability.
  • Add to reports mentioned in article 17.2, plans for multimodal transport options connecting storage sites to emitters as well as contributions to an EU-wide transport network for CO2.
  • The Net-Zero Europe platform must work to ensure EU-wide development of storage sites and increase collaboration among member states on the topic of CCS.
  • Provide greater clarity in terms of pricing of storage sites. To this end, the text must make provisions for transparency to avoid monopolistic tendencies.
  • Provide a supporting text on CO2 market regulation with a focus on transportation drawn up by 2025 to close the missing link in the CCS value chain.
  • Explicitly add clarifications on how failure to meet targets on the part of oil and gas producers will be penalised.
  • Conduct an impact assessment by 2025 on challenges and opportunities on inclusion of oil and gas imports to future storage injection capacity targets.
  • Include an explicit mention of emission reductions when referring to the environmental sustainability and resilience award criteria in public tenders.
  • Increase the weight of the environmental sustainability criteria to a minimum of 25%, with no upper limit, to utilise public procurement as a tool for decarbonisation.
  • Include embodied carbon within the sustainability criteria so as to promote the uptake of low-carbon materials to the market.
  • Ensure that the inclusion  of electrolysers includes conditionality; additional renewables with temporal and geographic correlation is necessary for their operation and contribution to climate action.


Read the full consultation response here: Bellona Europa Position on Net Zero Industry ACT (NZIA)

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