Abbiamo scritto al Joint Research Center dell’Unione Europea per esprimere le nostre preoccupazione rispetto alla bozza di normativa che potrebbe includere i combustibili ricavati da rifiuti come combustibili “rinnovabili” aprendo le porte ad una trasformazione massiva dei rifiuti in combustibili per il trasporto (e quindi la loro combustione) anziché il recupero di materiali (la cosiddetta economia circolare).
Ecco il testo della nostra lettera:
Monica.PADELLA@ec.europa.eu
Adrian.Oconnell@ec.europa.eu
Nicolae.SCARLAT@ec.europa.eu
Matteo.PRUSSI@ec.europa.eu
Object: Comments on the draft methodology for assessing greenhouse gas emission savings from Recycled Carbon Fuels (RCF)
Dear members of the EU Science Hub – Joint Research Center of Ispra, Italy.
We are a citizen association based in Collesalvtti (LI), Italy, which promotes cultural activities and a sustainable developmente of our territory.
After the announcement of the possible installation of a waste to methanol plant in a petrochemical plant in our area we have been studying the characteristics of this new kind of waste disposal and transformation plant, first from a technical and process point of view but in mainly regarding the implications that it might have in the waste management ecosystem long-term.
We are very concerned on the implications that accepting RCF in the scope of transport decarbonization objectives could lead to a very weak reduction of the overall GHG emissions and from another side it could create also a disincentive for waste reduction and recycling, which are the uttermost priorities especially in our region where the recycle is below national average.
We agree with the considerations of Zero Waste Europe on this topic and we ask you to evaluate carefully the following recommendations on how the GHG accounting methodology could be clarified and strengthened.
1. Establish pre-conditions to avoid competition with recycling
For the production of plastic to fuels, only plastic waste outputs from Material Recovery and Biological Treatment1 plants should be allowed to be used, as these separate out a larger portion of recyclable plastic from residual waste. Such a safeguard would avoid directing recyclable plastic downstream towards incineration and fuels production, in line with EU recycling targets and circular economy agenda.
2. Account for ‘diverted emissions’ in a separate formula
The formula of GHG emissions should cover total actual emissions for RCF’s and not account for emissions from diverting that input from existing use cases.
In other words, the absolute emissions of the RCFs should be reflected in the formula, since they describe the flow of fossil carbon to the atmosphere which exacerbates climate change. It is important to measure these emissions in order to reflect the real impact of the production and combustion of RCFs on the climate.
By focusing on the emissions coming from the production and combustion of RCFs rather than the relative comparison, the methodology will show exactly how much greenhouse gases were emitted to the atmosphere from the entire RCF value chain. This approach also reduces the risk of selective case picking; with a potentially unlimited amount of comparisons, there is a risk that stakeholders will compare their impact to the reference case which makes RCFs appear more favorable. Some fuel producers already claim that an expanded analysis should be used to ‘prove’ that they are directly displacing other fossil fuels in the market. Due to these risks, the suggested differentiation between the two formulas should apply regardless if the alternative uses would lead to net positive or negative emissions in the formula. A system expansion of an analysis can lead to different answers and in those cases cherry picking reference cases should be avoided (e.g. using an advantageous gCO2/kWh for electricity being replaced or counting emissions avoided elsewhere in the system). Instead, emissions from diverted inputs should be accounted for in a separate formula in which it is clearly indicated that the emissions are from comparing to a benchmark technology and not as emissions over the life cycle of RCFs. To summarize:
E1: actual life-cycle emissions: ei+ep+etd+eu-eccs
E2: comparative emissions in relation to benchmark technology: ei+ed+ep+etd+eu-eccs-erc
Where:
· ei= emissions from supply of inputs (gCO2eq / MJ fuel) [it should be further clarified what is included in ‘emissions from supply of inputs]
· ed= emissions from diverting inputs from its existing use (gCO2eq / MJ fuel)
· ep= emissions from processing (gCO2eq / MJ fuel). This should include emissions from processes such as fuel upgrade.
· etd= emissions from transport and distribution (gCO2eq / MJ fuel)
· eu= emissions from combusting the fuel in its end-use (gCO2eq / MJ fuel)
· eccs= emissions savings from carbon capture and geological storage (gCO2eq / MJ fuel)
· erc*= emissions saved by recycling CO2 (gCO2eq / MJ fuel)
*The Erc benefit should be preserved only for the utilization of CO2, since it’s an inert gas at the end of the energy cascade. Any carbon-containing material, gas or liquid that can be recycled, upcycled and has calorific value should be excluded from Erc (as elaborated in 5.)
3. Ensure upgrading RCFs are included in processing emissions (Ep)
When accounting for GHG emissions from processing RCFs they should include GHG emissions from upgrading of RCFs happening outside the plant boundaries. Upgrading of RCF’s is considered essential for vehicular applications with estimates that 53% of product carbon is lost in oil upgrading. Excluding those emissions can distort the true GHG emission intensity of the RCF process in comparison to the true emissions.
4. Use the formula for actual life-cycle emissions when assessing thresholds
When classifying transport fuel as low-carbon transport, a threshold of at least 70% saved emissions should be applied in order to comply with the aim to decarbonize the sector. For such calculations, the first formula E1 should be used. In other words, ‘avoided emissions’ from alternative uses of the input material should not be included. This would be misleading as it only shows emissions in relation to a benchmark technology. A high threshold and the use of the E1 formula to determine it would ensure that only truly low-carbon fuels are promoted through the REDII framework.
5. Emission saved by recycling carbon shouldn’t apply to RCFs
RCFs should not be credited emission savings as any fuel production merely delays the absolute emissions and in addition they have extra processing emissions on top. The fuels are essentially produced by refining a fossil source of waste which has calorific value, making it more analogous to energy recovery rather than recycling.
Moreover, the concept of ‘emissions savings from carbon recycling’ is misleading and contradicts the definition of ‘recycling’ as defined in the EU Waste Framework Directive (WFD). The WFD defines ‘recycling’ as “any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations”. Therefore, any energy recovery and fossil refining, including the development of transport fuels, cannot be considered as recycling and should be treated equally as the end result is always fuel combustion. Crediting carbon conversion to the production of fuels would therefore artificially put the fuel production higher up in the waste hierarchy while in fact both fall under the energy recovery category in the waste hierarchy.
6. Revisit your categorization of “rigid” inputs
Allowing for favorable climate impact accounting for plastic to fuel may inadvertently promote the use of the technology and thus increase demand for plastic waste streams. Plastic to fuels would compete with incineration for plastic waste input and thus increase demand. By assuming that municipal waste is a rigid output and that an increase in demand cannot be met by an increase in supply, you fail to account for the fact that there is still room for expanded infrastructure for incineration of plastic and other waste to meet this demand. To achieve recycling and especially plastic reduction targets, a more elaborate recycling and sorting scheme would send a price signal to reduce plastic production. On the contrary, the additional infrastructure for the disposal of unsorted plastic waste has the potential to create an unvirtuous cycle where continued growing production2,3 and disposal are self-reinforcing. Therefore, it should be reconsidered if municipal waste, plastic waste and other non-renewable waste streams should be classified as rigid inputs in this context.
We understand that you are in front of a tough decision with many conflicting interests, to find the optimum it is not trivial at all. We cannot and we don’t want to substitute in any way you from a technical point of view but we believe that here the decision is also political. The implications on accepting or not RCFs as a “green” source for the huge market of fuels could have unthinkable implications for the coming decades in the waste management ecosystem and then in the way we consume goods and things are produced. We hope that you’ll have the strongest sensibility on this topic.
Please let us know your thoughts on the abovementioned considerations.
We thank you for the important role you cover in the EU and we wish you all the best in this critical task.
Regards,
Cittadini in Comune per Collesalvetti
www.cittadinincomune.info
