ZEP has responded to the consultation on the Inception Impact Assessment on Hydrogen and gas market decarbonisation package highlighting: Acknowledgment of CO2 within the scope of the legislation is key to kick-start Europe-wide CO2 infrastructure; With CO2 infrastructure put in place, volumes of low-carbon hydrogen from natural gas with CCS can be made available; Thorough, scientific carbon accounting must be at the basis of any regulatory framework that will support the use of renewable and low-carbon gases – including low-carbon hydrogen produced with CCS.
ZEP responded to the questionnaire on the review of the REDII Directive. ZEP highlighted that the REDII should be amended in order to be consistent with the objective of net-zero GHG emissions by 2050 and with other relevant pieces of legislation. Coordination among different pieces of legislation is critical to deliver a cost-efficient transition to higher 2030 targets, as well as to the objective of climate neutrality by 2050. There is an increasing role for low-carbon hydrogen to play to meet both 2030 and 2050 targets. CCS can play a crucial role in delivering early, large-scale volumes of low-carbon hydrogen from reformed natural gas, which will be needed to achieve the higher EU 2030 emissions reduction target.
ZEP responded to the EU ETS consultation highlighting that the revision of the EU ETS will need to be aligned with climate neutrality by 2050 and deliver on the increased 2030 ambitions. The revision of the EU ETS directive will bear several consequences for CCS and CCU projects. As geological storage sites are not evenly distributed among member states, the large-scale deployment of cross-border, European CO2 transport and storage infrastructure is crucial to reach the European Union’s objective of net-zero GHG emissions by 2050.
ZEP responded to the consultation on the revised TEN-E Regulation, highlighting several key messages on carbon dioxide networks, CO2 transport modalities, CO2 storage, and the timely development of CO2 transport and storage infrastructure to kick-start a clean hydrogen economy for the EU, where early, large-scale volumes of low-carbon hydrogen are produced and delivered for industrial and residential use.
ZEP responded to the Innovation Fund consultation on an amendment of the delegated regulation to enable a choice between a one-stage or two-stage application procedure for the next large-scale call. ZEP’s input included a positive reply with reservations and some questions, and further comments ahead of the second large-scale call.
The guidelines need to be updated and aligned with the market developments and the more ambitious new climate agenda, the European Green Deal, the European Climate Law for climate neutrality by 2050, etc. CCS is essential for Europe to reach climate neutrality by 2050 in a cost-efficient way and may be the only alternative to decarbonise the many industries in hard-to-abate industrial sectors, such as steel, cement and chemicals. The European Commission’s consideration that “the aid for CCS contributes to the common objective of environmental protection” in order to promote the long term decarbonisation objectives has become even more valid.
ZEP is pleased to provide input to the consultation on the draft delegated acts, outlined as follows:
1. Comments on the principles of the European Taxonomy for Sustainable Finance
2. Hydrogen threshold
3. Electricity threshold
4. CO2 transport
5. Biomass with CCS
6. Waste-to-Energy with CCS
7. Carbon Capture and Utilisation
Revision of the EU ETS will need to be aligned with climate neutrality by 2050 and deliver on increased 2030 ambitions.
The upcoming revision of the EU ETS directive presents the opportunity to raise the ambitions of the EU ETS, aligning it to the objective of climate neutrality by 2050 and to the new, increased 2030 greenhouse gas emissions reduction target, as soon as the negotiations will be finalised. As noted in previous responses, ZEP believes that the 2030 target should put the EU on a cost-efficient pathway towards net-zero by 2050.