UFE’s reply to the public consultation on the draft delegated act setting out a methodology for assessing GHG emissions savings from RFNBO and recycled carbon fuels

UFE’s major concern on this draft relates to the emission intensity of the electricity produced in France set out in part C of the annex (Table A). The proposed value of 20gCO2e/MJ (equivalent to 72gCO2e/kWh) is very high and does not reflect the actual carbon intensity of the French electricity mix. As an alternative to the values set out in Table A, Member States should be allowed to use verified national data to prove the emission intensity of their production mix as accurately as possible.

UFE also recommends introducing a fifth alternative methodology for assessing GHG emissions savings, based on the hourly average carbon content of the national electricity mix of the country where the electrolyser is located.

As a minimum, to provide certainty to project developers, a grandfathering clause for the production of e-fuels using CO2 from industrial origin should be introduced to ensure that projects in operation and under development – which have a lifespan of 15 to 20 years – won’t be impacted by this provision.