Low-Carbon Delegated Act: Annex

Brussels, 18 December – In a letter to the new European Commissioner for Energy, Dan Jørgensen, civil society organisations urge the European Commission to strengthen the rules for hydrogen derived from fossil gas in the upcoming Low Carbon Delegated Act (DA). The letter highlights concerns about the proposed default value for greenhouse gas emissions related to fossil gas, which is based on inaccurate carbon footprint data. CAN Europe has compiled a list of relevant scientific data showing that gas and LNG imports are highly methane intensive across the entire supply chain, mainly up and midstream. To avoid any greenwashing the organisations call for science based and stringent rules for labelling fossil gas based hydrogen as “low carbon”. Read the full letter here, signed by CAN Europe, T&E, EDF, Deutsche Umwelthilfe, Bellona, and Sandbag.

Annex

A.Background information: Methane emissions from the upstream and midstream supply chain are a significant, yet often underestimated contributor to greenhouse gas emissions. Numerous scientific studies highlight that the current default value in the Low Carbon Delegated Act of 10,45-12,45 gCO2eq/MJ is equivalent to a 1,4 – 1,9% leakage rate maximum. This value does not reflect actual methane emissions occurring across the full supply chain in export countries to the EU. A number of reports (see below) indicate that methane leakage from gas production could be significantly underestimated, with a scientifically accurate figure closer to 3% or even higher as suggested by scientific evidence. This inaccuracy presents additional risks. The current draft for the Delegated Act suggests that the default value will be used until well into the 2030s for fossil based hydrogen so-called “blue hydrogen” produced in the EU based on gas imports. For fossil based hydrogen produced outside the EU and imported into the EU the default value will remain relevant even longer. A standard value that is not high enough will disincentivize producers from taking anti-leakage measures and could also steer investments away from renewables towards fossil based hydrogen projects, posing a serious risk to the EU’s decarbonization goals. B. Key scientific references demonstrating the need to adjust the default value proposed by the Commission in the Low Carbon Delegated Act: 1. Methane intensity from the US LNG supply chain

A study published in Nature Journal in March 2024, measuring “US oil and gas system emissions from nearly one million aerial site measurements finds that the “six-region weighted average is 2.95% (95% CI 2.79%, 3.14%), or roughly three times the national government inventory estimate”. It also looks at up and midstream emissions.
Research published by SCI (Where Science meets Business) in October 2024 entitled “The Greenhouse Gas Footprint of Liquefied Natural Gas (LNG) Exported from the United States” monitors the GHG footprint of the US LNG supply chain, identifying that upstream and midstream methane emissions are the largest contributors to the LNG footprint with emissions from tankers varying from 3.9% to 8.1%.

2. Methane intensity of fossil gas from other exporting countries

Tropomi Data from 2019 analysed by EGU (European Geosciences Union) and also published in a T&E report identifies the carbon-intensity and greenhouse gas emissions from the LNG supply chain of Europe’s largest import sources. This is particularly interesting as it does not only list the methane intensity of US LNG but also the methane intensity of gas imported from Algeria or Libya. There is a wide span in intensity values: they range from below 0,2% in countries such as Qatar, Kuwait, to 5% for US and Algerian gas imports and up to 20% for Iraqi imports.

3. Methane intensities of US and other imports into two major gas importing Member States, Germany and Spain

The IFEU report from 2023 explicitly looks at the methane emissions associated with LNG imports to Germany, the largest importer of fossil gas in the EU. It brings important additional information on methane intensity of gas extracted in other countries exporting to the EU such as Algeria (approx 27 gCO2eq/MJ), US (approx 22 gCO2eq/MJ) or Nigeria (approx 21 gCO2eq/MJ).

This study from our member organisations, Fundacion Renovables (only in Spanish) uses satellite data (Sentinel, MethaneSat, NASA etc) to analyse the methane leakages of gas imports to Spain. It shows similar results as the German study cited above in terms of the order of magnitude.

4. Additional References, mainly US based

MethaneSAT Data showing that US oil & gas methane emissions are over 4 times higher than estimated (31/07/2024)
Geospatial Life Cycle Analysis of Greenhouse Gas Emissions from US Liquefied Natural Gas Supply Chains | Energy | ChemRxiv | Cambridge Open Engage
Assessment of methane emissions from oil, gas and coal sectors across inventories and atmospheric inversions (Comparison of the different methodologies and sources including the USA)
2022: Methane emissions from US low production oil and natural gas well sites (https://www.nature.com/articles/s41467-022-29709-3)
2021: Closing the methane gap in US oil and natural gas production emissions inventories (https://www.nature.com/articles/s41467-021-25017-4)
2010–2015 North American methane emissions, sectoral contributions, and trends: a high-resolution inversion of GOSAT observations of atmospheric methane (published in 2021)

Find the ANNEX here.