The revised Renewable Energy Directive (REDII), adopted in 2018, establishes a common framework for the promotion of energy from renewable sources in various sectors. Throughout the past year, Bellona Europa has actively provided feedback to the European Commission on the implementation of the REDII. Notably, we provided feedback on:

• the Delegated act for the greenhouse gas accounting methodology for renewable fuels of non-biological origin (RFNBOs) and recycled carbon fuels (RCFs) and
• the Delegated act on the minimum thresholds for greenhouse gas emissions savings of recycled carbon fuels.

In order to ensure these fuels are indeed contributing to the climate goals of the EU, the GHG methodology for RFNBOs and RCFs used in the transport sector should give clear definitions and guidance for calculations in order to avoid misinterpretation and to ensure that all the relevant climate impacts of the fuels are counted.

Counting the emission intensity of electricity used for RFNBO production is vital.

This year, the EU has rolled out ambitious plans focusing on the deployment of hydrogen production. In order to help achieve climate goals and incentivise further integration of renewable electricity into all sectors, these projects need to be paired with an equivalent effort in the deployment of renewable electricity generation.

We fully support the precautionary principles outlined in the REDII which should be reflected in the final delegated act on the methodology for the calculation of the emissions from the electricity use for RFNBO production. We have therefore provided recommendations that seek to ensure that indirect emissions from electricity are fully counted. To ensure that the electricity used for RFNBO production can be counted as truly renewable, the production and consumption of electricity should be connected as much as possible.

In addition, a transitional phase loosening the sustainability criteria for RFNBO production should be avoided, as it provides incentives for projects which would not reach the 70% emission reduction outlined in the REDII. Different interpretations of the methodology cannot all achieve a 70% emission reduction over the same period. Hence it should remain the same throughout the period of the implementation of the Directive.

For hydrocarbon RFNBOs, specifying the source of the carbon is also necessary to assess their climate impact. Therefore, the methodology should differentiate between fossil and atmospheric or biogenic source of carbon to reflect the climate change mitigation potential of the fuel. Any fossil inputs, whether they are CO2 or fossil waste, used for the production of either RFNBOs or RCFs should be fully counted, as they are emitted into the atmosphere when the fuels are used in the transport sector.

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