Fachagentur Nachwachsende Rohstoffe e.V.
FNR
In Germany, FNR (Fachagentur Nachwachsende Rohstoffe e.V.)
ID: 282178211569-81
Lobbying Activity
Meeting with Jens Gieseke (Member of the European Parliament)
30 Jul 2024 · Austausch zu Umweltpolitik
Meeting with Jan-Christoph Oetjen (Member of the European Parliament) and Deutscher Bauernverband and
26 Jan 2024 · Visit to the fair "Internationale Grüne Woche" - Agriculture
Response to Update of list of sustainable biofuel feedstocks
2 Jan 2023
The Agency for Renewable Resources (FNR) welcomes the initiative of the European Commission to update Annex IX of the Renewable Energy Directive 2018/2001 (RED2). Broadening the feedstock basis is crucial if the EU wants to meet its climate and energy targets in the transport sector. However, with ambitious EU targets for sustainable transport, but also biogas and biomethane, the distinction between feedstocks for advanced processing technologies (Annex IX Part A) and mature technologies (Part B) becomes increasingly difficult. Comments: - The recommendations of the study Assessment of the potential for new feedstocks for the production of advanced biofuels commissioned by the EU have only partly been taken into account. - It is unclear why recital 4 of the draft Delegated Act (no feedstocks suitable for food and feed chain) is needed, as RED2 article 28 (6) has already a complete list of six criteria to be met. - Part A (t) requires clear and consistent definitions of non-food crops, not suitable for food and feed crops and a clarification of severely degraded land. - To be in line with existing national legislations and to maintain the confidence of investors, feedstocks currently in Annex IX Part A should not be moved to Part B. - Part B (j) and (p) require clear definitions - To ensure market transparency and a level playing field for all stakeholders, a uniform transposition into national legislation would be desirable.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
26 Oct 2021
The Agency for Renewable Resources (FNR) welcomes this roadmap initiative and supports the aim to clarify the role bio-based, biodegradable and compostable plastics can play to deliver on the commitments on a carbon neutral and circular economy. We like to point out that this initiative should aim for a fair assessment of bio-based, biodegradable and compostable plastics, which requires to understand the innovative character of these relatively new products which are often still available in a niche market. [1] This means also to take into consideration the high potential for further process and product improvement. Especially compared to fossil-based plastics, which are established products within a saturated market with less potential for product and process innovation. An unbalanced burden through legislative measures and requirements which will put bio-based plastics in a disadvantage while leaving the fossil-based plastics untouched needs to be avoided. Please find more detailed feedback attached.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
17 Dec 2020
In Germany, FNR is the central coordinating institution for funding research, development and demonstration projects in the field of renewable resources used to produce bio-based products and/or bioenergy. FNR 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 the draft delegated act makes some references to other pieces of EU legislation, synergies and coherence with current and future legislation should be aimed for more strongly, e.g. when it comes to the Common Agricultural Policy or the Renewable Energy Directive post 2020 (RED 2). E.g., 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 of 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.
- In line with Article 10 (2) of Regulation 2020/852, an economic activity supporting the transition to a climate-neutral economy should be seen in a more positive way. To achieve an impact on GHG reduction already in the short term (with short term and long term neither defined in the regulation 2020/852 nor the draft delegated act), it is important to rely also on technologies, which can create synergies with current intermediate and final products; and to take stock of the expertise as well as the financial and industrial capacity of present market actors. Examples are activities 3.16 (manufacture of plastics in primary form) and 4.13 (manufacture of biogas and biofuels for use in transport).
- 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 and immediate 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 in the energy system and for reaching climate targets also in the long term. Bioenergy can balance variable contributions of other renewable energies and will remain the main renewable energy source for heavy-duty transport, shipping and aviation for decades.
- 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).
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 here.
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