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European Technology and Innovation Platform Bioenergy

ETIP Bioenergy

The mission of the European Technology and Innovation Platform Bioenergy (ETIP Bioenergy) is to contribute to the development of cost-competitive, innovative world-class bioenergy and biofuels value chains, to the creation and strengthening of a healthy European bioenergy industry and to accelerate the sustainable deployment of bioenergy in the European Union through a process of guidance, prioritisation and promotion of research, technology development and demonstration.

Lobbying Activity

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

The European Technology and Innovation Platform Bioenergy (ETIP Bioenergy) aims to contribute to the development of cost-competitive, innovative world-class bioenergy and biofuel value chains, to the creation and strengthening of a healthy European bioenergy industry and to accelerate the sustainable deployment of bioenergy in the European Union, through a process of guidance, prioritisation and promotion of research, technology development and demonstration. ETIP Bioenergy fully supports the ambition of the Green Deal for net climate neutrality in 2050, as well as increasing the GHG emission target to at least 55 % in 2030. Also the initiative to create a classification system for sustainable economic activities (‘taxonomy’) is very welcome. Remarks: - Although some references are made to other pieces of EU legislation, synergies and coherence with current and future legislation should be aimed for whenever possible, e.g. when it comes to the Common Agricultural Policy or the Renewable Energy Directive post 2020 (RED 2). - Full alignment with the sustainability criteria of RED 2 is important. Updates of RED 2 could then automatically be reflected in the taxonomy screening criteria. - Excluding the use of food and feed crops in general does not reflect several innovative approaches for sustainable supply (cover crops, cultivation marginal lands etc.). Innovative practices (e.g., crop rotation, cover crops, agroforestry, etc.) that can restore carbon in the soils and provide additional raw materials for bioenergy and biofuels can be linked to and harmonised with RED 2. - Classifying bioenergy and biofuels as "transitional activity", which can only be supported if there are no technologically and economically feasible low-carbon alternatives, is not justified in our view, as modern bioenergy can lead to significant GHG reductions. This refers to the energy applications of solid, gaseous and liquid biomass (for electricity and/or heat production, as well as for transport biofuels – see Annex I, 4.8, 4.13, 4.19, 4.20, 4.24). This classification as “transitional” would also disqualify research, development and innovation on bioenergy (see Annex I, 9.1). In scenarios of the International Energy Agency (IEA) and the Intergovernmental Panel on Climate Change (IPCC), sustainable bioenergy has an important role for reaching climate targets also in the long term. - The focus on zero tailpipe CO2 emissions in transport (section 6) is wrong in our view. Instead of focusing on zero tailpipe CO2 emissions a well-to-wheel approach must be considered. Reducing CO2 emissions in transport is one of the biggest challenges for the European Union. To ensure the contribution of the transport sector to the overarching EU targets of -55 % GHG in 2030 and net carbon neutrality in 2050, all options will be needed, including low carbon fuels. A significant reduction can only be achieved if low carbon options are implemented in the existing vehicle fleet, be it road or maritime transport as well as aviation. Renewable fuels can also offer very positive effects on harmful emissions (PM, NOx, SOx). Moreover, solutions with no CO2 emissions at the tail pipe can however contribute negatively to GHG emissions when analysed from cradle to grave illustrating that only focusing on CO2 emissions at the tail pipe is the wrong approach. - 4 weeks is not an adequate timespan to read and digest the 529 pages of the Delegated Act and its Annexes, which are crucial for this piece of legislation. - The EC’s better regulation agenda stipulates that “the delegated act cannot change the essential elements of the law”. It can be questioned if this principle is respected when reading Article 1 “Subject matter and scope” of the Sustainability Regulation 2020/852.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

The European Technology and Innovation Platform Bioenergy (ETIP Bioenergy) would like to confirm the position that biofuels have the potential to contribute significantly to the energy transition, in order to achieve a reduction of CO2 emissions from cars and vans cost-effectively, in line with the European Green Deal and in line with the EU’s commitment to global climate action under the Paris Agreement. Electricity and hydrogen are expected to expand drastically in transport in the next decades, to allow the carbon footprint of transport to align with the global objectives of mitigating climate change. However, the pre-eminence of liquid, fossil fuels will not be challenged in the mid-term, implying efforts should be strengthened to reduce the intrinsic carbon footprint of liquid fuels, in coordination with the on-going efforts towards improving the energy efficiency of engines (as lower fuel consumption implies lower CO2 emissions). An integrated bio-based technology development strategy (and also exploiting synergies in combining biomass (BTx) and electricity/power (PTx) based technologies) can help to stay on track to reach climate and energy targets in time. In addition, the standardisation of novel fuels plays a major role to ensure a swift reduction of the carbon footprint of the transport sector and harmonisation ensures a common European basis of transport options. Renewable hydrocarbons (e.g. HVO, BTL, biomethane) have the considerable advantage that their similarity to fossil hydrocarbons implies that no adaptation to, either distribution infrastructure, or existing engines, is necessary. As such, their development should be a priority. An integrated approach of strong policy measures, research, innovation and improved financing solutions is necessary. The climate targets, RED II, FQD, AFID and vehicle CO2 regulations should be coherent and aligned to deliver significant GHG emission reductions for Europe in a cost effective way. The internal combustion engine will be part of the energy transition and therefore sustainable biofuels as well. Strong sustainability criteria for biofuels and their feedstocks are essential. R&D efforts are also needed to properly assess the sustainability of biofuels (which includes the low-ILUC concept development). With regard to sector coupling, Life Cycle Analysis and well-to-wheel approaches should be considered when assessing CO2 emission reduction to ensure a level playing field. The recently published JEC Well-To-Wheels report concluded that the HVO pathway with the DICI Hybrid technology (waste as feedstock) and the use of compressed biomethane in a SI MHEV represent the lowest GHG routes, including zero-emission vehicle pathways with electricity and hydrogen. The EU should encourage Member States (MS) to take an overall harmonised approach and to strive for the highest share possible (within the 7% limit) of sustainable conventional biofuels. There will still be a certain flexibility for each MS, concerning to which extent different types of biofuels (conventional, advanced, renewable hydrocarbons) will be used to reach this target. In addition, the EU should be encouraged to increase the 14% target in line with the 2030 Climate Target Plan impact assessment. All alternative energies are needed to reduce emissions in the transport sector in line with the Paris Agreement!
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The European Technology and Innovation Platform Bioenergy (ETIP Bioenergy) fosters the position that the biofuel sector has the potential to establish the energy transition in order to achieve the climate targets for the upcoming decade as targeted by the European Green Deal and in line with the EU’s commitment to global climate action under the Paris Agreement. In addition to the current focus on electric and hydrogen vehicles, advanced drop-in type biofuels offer a “fast track” type option for decarbonising the transport sector. Aspects like the change out rate of the vehicle fleet, the need for new infrastructure, GHG emissions from power generation, and possible scarcity of some key materials for battery production, emphasise the continuing need for advanced biofuels in the transport sector within the next decade. A more constructive approach forward would be to identify and pursue the synergies between electro-mobility, hydrogen and biofuels. The specific 14% renewable energy target set in the REDII for the transport sector is positive, but by far not enough. It is vital that the 14% target will be met on time and not watered down by multiple counting. Consequently, sustainable conventional biofuels are needed preferably at 7% level. The focus should be put on continued improvement and development of these and their sustainability and not on banning existing biofuels. Further, it is important to count only actual biofuels volumes and to limit multiple counting to the extent possible. Double counting of advanced biofuels are essential in the first phase of the Directive to favour advanced biofuels deployment, however, in the long term, double counting will undermine the targets and leads to virtual renewable energy amounts. True greenhouse gas savings can only be achieved through the physical deployment of renewable fuels. Key Recommendations: • Ambition in renewables: The 2030 targets for renewables (total energy and energy for transport, increasing respectively to 32% and to 14%) are welcome since renewables have an important role to play in the energy decarbonisation and transition. However, they will probably need to be increased to meet the targets set by the Paris Agreement in 2015. • Increasing role for biofuels: Renewable fuels and especially biofuels are key to help reducing the carbon footprint in transport segments that will continue to rely on internal combustion engines, and are complementary to new mobility modes that are expected to make a significant market impact. An integrated bio-based technology development strategy (and exploiting synergies in combining biomass (BTx) and electricity/power (PTx) based technologies) can help to stay on track to reach targets in time. • An EU-wide determination: The EU should encourage Member States (MS) to take an overall harmonised approach and to strive for the highest share possible (within the 7% limit) of sustainable conventional biofuels. There will still be a certain flexibility for each MS, concerning to which extent different biofuels will be used to reach this target. In addition, the EU should be encouraged to refrain from using the option to decrease the 14% target, (if conventional biofuels share is below 7%). All efforts are needed to reduce emissions in line with the Paris Agreement! • Strong R&I strategy for advanced biofuels: An integrated approach of strong policy measures, research, innovation and improved financing solutions is necessary. The internal combustion engine will be part of the energy transition and therefore sustainable biofuels as well. • A robust sustainability is mandatory: In addition, strong sustainability criteria for biofuels and their feedstocks are essential, and R&D efforts are also needed to properly assess the sustainability of biofuels (which includes the low-ILUC concept development). With regard to sector coupling, well-to-wheel approaches should be considered when assessing GHG emission reduction.
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Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

1 Mar 2019

I am providing the views of the members of the "European Technology and Innovation Platform Bioenergy" (ETIP Bioenergy). The opinions about the draft Delegated Act on high and low ILUC are summarised in the attached pdf file. Best regards, Kristin Sternberg on behalf of ETIP Bioenergy
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