This technical report provides input to the European Unions Commissions work on the delegated acts related to the carbon removal certification framework and provides specifically technical context to the calculations of GHGassociated. Specifically it refers to calculations of “GHGassociated” and “the 25% issue”.

The ICF draft methodology provides problems in relation to real life design of BECCS facilities through definitions provided in chapter 4 which is not demanded by CRCF chapter 2 1.c. These formulation leads to perverse incentives where design of capture facilities might be adopted to optimize calculation procedures rather than provide technoeconomic efficient designs of the physical capture facilities. There is also a double accounting problem as LCA emissions from biomass used as well as electricity, steam and/or heat generated by the same biomass can be interpreted to be included in the calculation of GHGassociated.

When designing a BECCS capture facility, energy can be used, recovered and generated as part of the capture process. There are many examples of such applications covering different capture technologies. Some are more integrated to heat flows, while others rely on mechanical work and thus are more integrated to either electricity or steam cycles. This text provides three examples related how to technically design the pressurization step of a pressurized capture technology. Similar examples can be provided for other parts or technologies upon request, but these should illustrate the problem.

All what is stated here refers to BECCS applications but should also be considered for DACCS methodologies.