EuLA (2018): EU ETS position paper on how to consider biomass when updating the lime & dolime product benchmarks in Phase IV
Article 10a (1) of the Directive 2003/87/EC empowers the Commission to determine Union-wide ex-ante benchmarks so as to ensure that allocation takes place in a manner that provides incentives for reductions in GHG emissions and energy efficient techniques, by taking account of the most efficient techniques, substitutes, alternative production processes, high efficient cogeneration, efficient energy recovery of waste gases, use of biomass and capture and storage of CO2 and shall not provide incentives to increase emissions.
The starting point shall be the average performance of the 10% most efficient installations in a sector in the Union in the years 2007-2008. For the period from 2021 to 2025, the European Commission shall determine a reduction rate that will apply to the initial benchmark value, based on the 2016-2017 emissions.
The 10% most efficient sub-installations determining the EU-level benchmark will consist of sub-in-installations burning almost only biomass although this fuel represents only 5% of the fuel mix used in the EU lime sector. More precisely, the EU-level benchmark for lime in Phase IV could be determined to a large extent by (very) small sub-installations (using only biomass as a fuel) exclusively in Southern Europe due to very specific local conditions.
EuLA supports that the EU-level benchmarks must reflect the situation across the EU and must not result from a limited geographical situation that cannot realistically be applied everywhere.
The use of biomass should be considered in a way that reflects overall sustainable use in Europe.
The lime benchmark update for Phase IV should be derived from the most efficient technology (i.e. the Parallel Flows Regenerative kiln) and from the emission factor of natural gas reduced by a percentage equivalent to the Union-wide proportion of biomass in the fuel-mix.
This would result in an improvement rate (note that 75% of the CO2 emitted by the lime industry are irreducible process-related emissions resulting from the decarbonation of limestone).