LSB position on the EC’s proposal to amend the renewable energy and fuel quality directives

In a press release of July 9th the Leaders of Sustainable Biofuels have expressed their support to the EC’s proposal to amend the Renewable Energy and Fuel Quality Directives, while warning of possible threats related to the extension of eligible feedstock for the production of advanced biofuels.

The EC amendment proposal was published in October 2012 with the aim of limiting the global land conversion for biofuel production improving the climate benefits of biofuels used in the EU. The proposal is currently under discussion in the European Parliament and voting in the lead committee ENVI is scheduled for July 11th.

In this regard the LSB:

  • welcome the statement to support advanced biofuels and support a gradual phasing-in of advanced biofuels mandated targets to 2020 and an increasing trajectory beyond 2020 (1)
  • support the ILUC principle, however a more in depth study must firstly be carried out to evaluate the true indirect effects of biofuels
  • foresee a threat in the extended list of feedstock eligible for advanced biofuels especially on the use of animal fats (2) and used cooking oil, palm oil residue/waste and any other food feedstock derived residue/waste from the oleochemical, biodiesel and vegetable oil refining (3)
  • believe that feedstock eligible for advanced biofuels such as residue/waste derived from oleochemical, biodiesel and vegetable oil refining processing (3), where non-advanced / non-sustainable feedstock such as palm oil is used, is absurd and is counter-productive to the objectives of this legislation.

According to LSB such feedstock clearly need to be excluded from the definition, as their inclusion would open the door to unsustainable  biofuels from food and feed crops and the objective of a long-term development of feedstock used for advanced biofuels not competing with food and feed products will be clearly jeopardized. The consequences of such a questionable broadening clause and the foreseeable misdeclaration of feedstock will be received very negatively by the general public and will bring industry, the product itself and last but not least political decision makers into discredit.

Thus, the Leaders of Sustainable Biofuels strongly believe that it is essential for an effective implementation of the proposal, that the feedstock eligible for advanced biofuels production are  lignocellulosic derived (i.e. straw, bagasse, EFB, forestry residues, crude tall oil & tall oil pitch), or manufactured from the biomass fraction of municipal wastes, truly sustainable and that the potential for fraud has to be excluded.

Read the full press release.

(1) ITRE OPINION 31 Article 2 – point 2 – point c
(2) ITRE OPINION 45 Annex II – point 3 (p)
(3) ITRE OPINION 45 Annex II – point 3 (s, t, u, w)




 

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