BioDriv Öst
BioDriv Öst är ett storregionalt nätverk som ska underlätta och påskynda omställningen till förnybara alternativ i transportsektorn.
ID: 711654440737-64
Lobbying Activity
Response to Climate change mitigation and adaptation taxonomy
18 Dec 2020
Whilst well-intended, we are worried that the EU taxonomy could have unintended effects that undermine essential technologies and ultimately hinder the decarbonization of the European economy. As the criteria proposed in especially Annex 1 to the Taxonomy Delegated Regulation are written they raise several concerns
Our main concerns are:
Comment on 4.13. Manufacture of biogas and biofuels for use in transport
Biogas and biofuels with high sustainability performance are important in the transition towards a fossil-free transport sector. Sustainability performance for biogas and biofuels depends on several different factors in the product’s lifecycle: feedstock origin, methods and co-production in the biorefineries, and end-use efficiency. In the draft delegated act biogas and biofuels for the use in transports are noted as “transitional” activity without considerations to the whole value chain and due scientific explanations. This is in sharp contrast with REDII, where specific criteria is set, in order for bioenergy to be sustainable.
Comment on 6.3. Urban, suburban and road passenger transport
Vehicles with tail-pipe emissions up to 50g CO2 eq/km are included to 2026, and 0 g thereafter. We strongly object to using “tail-pipe” as all fuels cause emissions somewhere, there are no zero emission fuels, and all should be treated equally. Well-to-wheel (WTW) is a more appropriate selection method to tackle climate change.
Impeded innovation
The very concept of a long, detailed list of sustainable activities introduces the risk that innovation will be hampered. We know that new technologies will play an important role in decarbonizing society, but these are not necessarily included in the list. Even if the list will be revised regularly, its existence introduces new risks for innovators.
We have identified the following three main consequences that the draft delegated act will have upon us:
Decreased energy security
The draft delegated act discourages investments in biofuels. Sustainable produced biogas and biofuels for transports can greatly increase energy diversification in the EU while at the same time helps decarbonize the transport sector and creates new green jobs. Investments in sustainable biogas and biofuels should be a priority for the Union in order to decrease the overall reliance on imported fuels, or fuel precursors (fossil fuels, feedstock for biofuels, biofuels, battery components and batteries). An increased production of fuels in the EU will also contribute to the overall energy security in the electricity sector.
It makes it even harder to reach set climate goals
Decarbonization of the transport sector will take much longer if biogas and biofuels, and vehicles using them, are ruled out. As stated before, it is naturally of great importance that the biogas and biofuels, as well as battery production and electricity for EVs, are sustainably produced. We understand the, otherwise inexplicable, focus on tailpipe emissions from vehicles to be a direct consequence of the misconception of sustainable bioenergy as being “transitional”.
It discourages a unified energy transition strategy
In the Green Deal the Sector integration is an important strategy. Linking the sectors buildings, transport and industry will lead to the optimization of the whole energy system. This means that the decarbonization will be achieved in the whole energy system rather than in each sector independently. We fear that the EU Taxonomy holds a risk of defragmentation of the sectors. This as each sector will have to find its own threshold value, in order to be taxonomy aligned which does not facilitate sectoral integration.
We propose the following solutions:
The removal of the word “transitional” in all references to bioenergy
That the criteria set out in the delegated acts should be fully aligned with relevant EU acquis, most notably the sustainability criteria in REDII
Use WTW-emissions rather than tailpipe emission
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