OpenLobby.EU
Explore

Association of Industry, Agriculture and Services

AIAS

Strong Slovak business organization with international exposure.

Lobbying Activity

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Envien group is the largest biofuels producer and market leader in CEE region with production capacities in Slovakia, Czech Republic, Hungary and Croatia, with cumulative production to be ranked: • as 9th biggest within the ethanol production in EU (250.000 m3) • as 10th in production of FAME in EU (280.000 t) Envien Group strongly welcomes the upcoming revaluation of the EU Climate and Energy policies and supports the potential revision of the Renewable Energy directive in order to foster the uptake of renewable energy in Europe, reduce reliance on fossil energy and support the European Green Deal Ambitions. In order to support maximum uptake of renewable energy, the revised legislation should boost deployment of all sustainable renewable energy sources, not putting renewables against each other and thereby hindering greater renewable energy incorporation. EU should foster deployment of new emerging technologies while fully benefiting from all currently available sustainable solutions, such as biofuels from EU feedstock. Low carbon renewable liquid fuels such as domestically produced bioethanol and biodiesel constantly deliver high GHG emissions savings and offset fossil fuels reliance. At the same time they significantly contribute to protecting farmer`s revenues and hence preserving food security. Key recommendations: • Increase ambitions for both overall renewable energy target and renewable energy in transport to propriate levels which will ensure the projected emission reduction. Ideally there should be separate targets for renewables in all transport fuels, e.g. separate targets for petrol and diesel. • Cancel or at least significantly lift the cap for first generation biofuels. As the ILUC concern was already addressed in the Delegated Act for high-ILUC biofuels where palm oil is categorised as high ILUC risk and should be phased out, then all other sustainable 1G biofuels should contribute to maximum extend to the ambitious renewable targets. European crops do not drive deforestation, and only high ILUC risk biofuels must be limited. At the same time crop biofuels production provide locally produced fodder and is garant of the EU protein security. • Eliminate multiple counting on several renewable energy sources which artificially increases the RES-T target fulfillment but is counterproductive as for the real emissions saving. • Support progressive deployment of advanced biofuels by setting the targets on real but ambitious levels, based on analysis of existing and prepared production capacities so that they stimulate development of 2G industry but aren`t too high to be achieved and so demotivating. If the list of feedstocks for production of advanced biofuels is to be added, then the targets must be accordingly adapted. • Strengthen sustainability criteria in line with the European standards for agricultural production, GMO policy, waste prevention and management standards, and strict traceability requirements. • To secure an ambitious and stable policy framework with policy continuity and visibility beyond 2030. The fulfillment of preliminary targets must be ensured and properly checked, if not the case then sanctions must be implemented and enforced. • Support automotive to fully use the capabilities and potential of internal combustion engines to deliver higher emission reduction. Climate target 2030 indicates the beginning of discussion on internal combustion engines phase out. We regard this discussion as absolutely inappropriate in situation when no other technology is fully ready to replace existing one (even in longer term). We are persuaded that due to existing technological limits of electrification or hydrogen the usage of internal combustion engines will play significant role at least until 2050 and this needs to be reflected also in the new RED directive. • Incorporate life-cycle approach when counting CO2 emissions from transport.
Read full response

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

20 Apr 2020

Dear all, Thank you very much for the opportunity to comment on this policy initiative. I`m writing you on behalf of Envien Group, the biggest Central and Eastern European biofuels holding with production facilities in Slovakia, Czech Republic, Hungary and Croatia. Our group currently employs cca 500 people and in 2019 we have produced more than 230.000 m3 of bioethanol and more than 250.000 t of biodiesel including waste-based biodiesel with up to +90% GHG reductions, thus enabling “near-term decarbonisation” of the EU road transport sector. The Commission’s inception impact assessment (IIA) “ReFuelEU Aviation - Sustainable Aviation Fuels” sets out the Commission’s early thinking about a future legislative instrument to promote Sustainable Aviation Fuels (SAF). The IIA lists several measures that could be included in the draft legislation to promote SAF, including a blending mandate and prioritization measures to direct road liquid transport fuels towards aviation, among others. UCO-based biodiesel (UCOME) and animal fats (tallow)-based biodiesel (TME) are produced in energy efficient conversion processes with advantageous GHG emissions reductions compared to the use of same feedstocks for aviation purposes, as established in Annex V of the Renewable Energy Directive. Waste biodiesel production processes do not modify the carbon chain of feedstock molecule and therefore it cannot be used as jet fuel given its cold flow properties. Our industry believes that the upcoming legislative instrument to promote SAF should exclude UCO and animal fats from a possible aviation target or any other similar promotion measure. In addition, prioritization measures should not target waste biodiesel using feedstocks such as UCO and animal fats currently being used by the EU road sector. There are several reasons supporting why UCO and animal fats feedstocks should be excluded from SAF incentives: No investment where it is needed - If UCO and animal fats are included in aviation incentives, given the existing feedstock volumes and technological development they will populate the whole new protected fraction of the market and completely disincentivize any possible investment in novel technologies/feedstocks such as those in Part A of Annex IX or others not even included in the Annex yet. Less GHG savings - UCO and animal fats-based biodiesel production is more efficient and less energy intensive than HVO/HEFA/HEFA+ production and therefore it has higher GHG savings than UCO and animal fats based HVO as established in Annex V of the REDII. In fact the difference is actually higher as the values in Annex V relate to roadworthy HVO and not airworthy HVO, known as HEFA+, which is even more energy intensive to produce and has therefore less GHG savings. In addition to that - in aviation there is a 1,2 multiplayer applied which leads to lower absolute GHG savings then if used in road transport. Economic damage - Prioritization and indiscriminate incentivization of SAF would lead to the destruction of the waste biodiesel industry, creating economic damage in the majority of Member States. UCO collectors and waste management networks will eventually be negatively affected as well as the buyer base of their products will be reduced to a handful of refineries in a favorable price-setting position. No near-term decarbonization of the road transport sector - Member States would lose waste biodiesel as a key enabler of near term decarbonization of their road transport. Thank you once again for taking our comments into consideration!
Read full response

Meeting with Vladimir Sucha (Director-General Joint Research Centre)

26 Jun 2018 · Meeting with Ms Mamrillova representing Association of Industry, Agriculture and Services and one of is members- Envien Group, active in the production of biofuels, to exchange views regarding the EU approach o 2nd Generation and Advanced Biofuels made from non-food feedstocks and the underpinning JRC research in the area.