ESWET response to the EU Commission on permanent CCU consultation

The role of Waste-to-Energy in Carbon Capture (CC)

Given Waste-to-Energy’s proposed inclusion in the upcoming EU Emission Trading System (ETS), the potential for Carbon Capture and Utilisation (CCU) to be recognised under this will have a significant impact on the business case for future CCU projects in the Waste-to-Energy (WtE) sector.

As a hard-to-abate industry with a capture potential of 60-70 million tonnes of CO₂ per year in Europe alone as per the Intergovernmental Panel on Climate Change (IPCC), ESWET welcomes this Delegated Act given the centrality of carbon capture to the sector.

WtE is ideal for carbon capture as approximately 58% of its emissions are biogenic, giving huge potential for negative emissions. This makes WtE the sector with the second-largest potential for capturing biogenic emissions in Europe.

Treating products that are at “end-of-life” stage means that there are no sustainability issues which may occur with the sourcing of other forms of bioenergy, where crops are grown specifically for energy production. WtE is a more financially secure means of carbon capture, given that plants are paid to treat waste so the energy penalty is not as significant to the business case.

Examples of successful Carbon Capture in WtE Plants

The synergies of carbon capture and WtE are proven. The AVR Duiven WtE plant in the Netherlands has a capture capacity of 100,000 tonnes CO₂ per year, with the carbon being used in local horticulture.

Also in the Netherlands, the Twence facility will soon be capturing up to 100,000 tonnes CO₂ per year, while the Klemestrud WtE plant in Norway has a planned installation to capture 400,000 tonnes of CO₂ per year.

Recognition and limitations of mineralisation in the draft Delegated Act

Due to the rapidly expanding carbon capture capacities of WtE plants, we appreciate the certainty that this Delegated Act provides in incentivising CCU projects.

We welcome the prioritisation of mineralisation in Article 3.1(a) given its ability to permanently store CO₂, although worry that the term “construction product” is narrow, given that products which are not strictly for “construction” may also permanently store carbon e.g., remediation materials which may be used for pollutant removal.

Additionally, in the future we would like to see a specific framework for non-permanent CCU in hard-to-abate sectors such as WtE, which would incentivise CCU in industries which have no simple means of abatement rather than risking “lock-in” of industries which have alternatives.

The full ESWET position paper can be found here.