CAN Europe’s input to the stakeholder consultation on the methodology to define low carbon fuels

On September 27, 2024, the European Commission opened a public consultation on the methodology to determine the greenhouse gas (GHG) emission savings of low-carbon fuels, which ends today, October 25, 2024.

CAN Europe welcomes the opportunity to provide feedback on the draft Delegated Act proposed by the Commission to underline and express our deep concerns regarding the promotion of so-called low-carbon fuels. The definition proposed by the Commission risks undermining the EU’s long-term decarbonization goals. The reliance on “low carbon” fuels (LCF), fossil-based with Carbon Capture and Storage (CCS) or produced from nuclear energy, diverts critical attention and financial resources from renewable hydrogen (produced by solar and wind), which should be the primary and exclusive focus. 

We consider it crucial to rethink the draft Delegated Act based on several guiding principles:

1. No fossil-based hydrogen in the absence of adequate methane measurement.
2. CCS cannot clean up the act of fossil-based hydrogen.
3. LCFs need an end date aligned with the 2035 gas phase-out objective, and the greenhouse gas emission reduction factor for LCF needs to be increased in the meantime.
4. No expansion of fossil gas supply to produce hydrogen.

The use of historical grid emission intensities should not be allowed when calculating the emissions intensity of low-carbon fuels

Read here our full input, submitted on October 24, 2024.