German Renewable Energy Federation
BEE
The German Renewable Energy Federation represents associations and companies across the renewable energy sector.
Lobbying Activity
German Biogas Association urges 100 bcm target for 2040
15 Sept 2025
Message — They support the 90% target but demand a 100 bcm biogas goal for 2040. The group opposes international carbon credits to maintain focus on domestic energy production. They also request the launch of a European Biogases Charter by 2025.123
Why — A production target would increase market demand and investment for biogas producers.4
Impact — Fossil fuel firms lose if carbon capture is restricted to specific hard-to-abate sectors.5
German Renewable Energy Federation demands priority for green hydrogen.
25 Oct 2024
Topic — This consultation defines a greenhouse gas emissions savings methodology for low-carbon fuels.
Message — The federation demands renewable hydrogen products always take priority over low-carbon alternatives. They suggest raising the default value for methane emissions to encourage actual measurement.12
Why — Priority network access and consumption quotas would secure market dominance for renewable producers.3
Impact — Nuclear and natural gas hydrogen producers face higher costs and stricter certification requirements.4
German renewable energy group urges broader bio-fertilizer rules
15 May 2024
Topic — Amending the Nitrates Directive regarding nitrogen fertilizers recovered from animal manure.
Message — The federation demands a technology-neutral approach that includes more types of recycled fertilizers. They argue classification should be based on chemical properties rather than production methods.12
Why — Biogas producers would benefit from higher demand for their recycled nutrient products.3
Impact — Synthetic fertilizer manufacturers would lose market share to these recycled organic alternatives.4
Meeting with Ditte Juul-Joergensen (Director-General Energy)
19 Mar 2024 · Energy market
German renewables federation urges higher nitrogen limits for digestate
7 Mar 2024
Message — The group questions whether a revision is sensible at this point in time. They want to allow digestate use above the current limit of nitrogen levels. They request support for technologies that recover nutrients through circular economy processing.123
Why — Biogas producers would see increased demand and value for their processed digestate.4
Impact — Organic farmers currently suffer yield losses due to restrictions on organic fertilizers.5
Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)
19 Dec 2023 · - state of play: EU solar industry - need for resilience capacity
Response to Count your transport emissions: CountEmissions EU
15 Nov 2023
The German Biogas Association (FvB) welcomes the European Commissions proposal for a Regulation on the accounting of greenhouse gas emissions of transport services, which sets a common regulatory framework for GHG emissions. Good is that a technology neutral and science-based approach (i.e., a Well-to-Wheel (WtW) methodology) is adopted so that it allows for a complete assessment of the environmental impact of the energy used in transport operations. It would be good if this approach could be used in any legislation, replacing the tail-pipe approach that does not account for all emissions during a life-cycle. However we have some suggestions for improvement: First, in order to ensure a quick and efficient decarbonisation of the multimodal transport chain as a whole - also thanks to the use of sustainable biogases - the proposal should develop a sound and coherent default values database: the EEA should based on the default values set in Annex VI of the Renewable Energy Directive expand the list to additional biogas and biomethane production pathways covering additional feedstocks (e.g., catch/cover crops, sequential crop grasses, industrial residues), carbon capture and reuse, and new technologies. The database must be periodically reviewed via Implementing Act, after a thorough consultation of national experts and stakeholders from the value chain. Secondly, it should be mandatory to apply the CountEmissions EU: After a transitional period, the Regulation should require businesses providing transport services to measure and disclose their GHG emissions under the CountEmissions EU framework. Moreover, it would be beneficial to introduce specific reduction target for the economic entities covered by the Regulation. Sustainable biomethane as a transport fuel represents one of the few ready-available, local and cost-competitive alternatives to conventional fuels for all transport modes, especially for energy intensive segments (heavy duty, maritime and, in the near future, aviation). Able even to achieve negative emissions, biomethane represents a key solution in the transition towards a climate neutral economy and can play a strong role to de-risk the shift from fossil to renewable energy. As asserted by the JRC, the WtW approach is the most appropriate methodology to properly assess the climate impact of different technologies. Nevertheless, a number of EU legislative pieces currently apply a restrictive Tank-to-Wheel (TtW), or tailpipe approach, which totally disregards the available shares of renewable fuels, such as biomethane, and their contribution in reducing CO2 emissions in all transport modes, especially in the more energy intensive ones.
Read full responseGerman Biogas Association warns against biodegradable plastic packaging
24 Apr 2023
Topic — The European Commission is reviewing packaging requirements to improve recycling and reduce waste.
Message — The GBA argues that anaerobic digestion is not a suitable recycling method for any packaging. They highlight that biodegradable plastics offer no biogas potential and can damage plant machinery.123
Why — Excluding these materials prevents operational damage and ensures the production of high-quality organic fertilizers.45
German Biogas Association Urges End to Technology-Based Feedstock Caps
22 Dec 2022
German Biogas Association urges equal treatment in EU permitting
27 Jul 2022
German Biogas Association seeks faster permitting in EU emissions overhaul
23 Jun 2022
Topic — This initiative aims to update industrial emissions legislation for a more sustainable economy.
Message — The association wants the EU to reduce complexity and accelerate permitting processes. They suggest avoiding mandatory environmental performance limits and differentiated standards for existing plants.12
Why — Lowering compliance requirements reduces financial and personnel burdens for biogas plant operators.3
Impact — Public authorities face increased strain from expanded monitoring and administrative inspection duties.4
Response to Revision of EU rules on Gas
12 Apr 2022
The German Biogas Association (GBA) welcomes the fact that the EU Commission wants to regulate, facilitate and expand market access for renewable gases – including hydrogen – in the common market. However, in the draft proposal there is no distinction made between renewable, low-carbon or fossil-based gases. That counteracts all efforts to come to a 100 % renewable and fully decarbonised energy market as foreseen for 2050. That’s why GBA suggests to amend the draft proposal as proposed in the attached paper. All in all biomethane and Bio-LNG can contribute to the energy transition and to security of supply, however, there must be prospects and political will to do so so that new investments will be made. Clearly, there must be stated that the goal is to have as soon as possible 100% renewables and a clear phase-out for fossil and nuclear-based energy.
- GBA welcomes that it is possible to give tariff discounts for renewable gases. Art. 16 states that when setting tariffs, a discount for renewable and low carbon gases shall be applied.
In addition, GBA thinks it vital to have a “right to inject into the gas grid” for renewable gases. Thus, GBA welcomes a priority connection for renewable gases as well as a firm capacity ensured to biomethane producers by grid operators. Permits must be granted in a set time interval (e.g. 3 months).
- GBA welcomes that long-term contracts for unabated natural gas cannot exceed beyond 2049 (art. 27.2). It is good, that there is an end-date for long-term fossil gas contracts, but interim targets would help the energy transition and ensured investment security. Thus, GBA suggests to include interim targets of defossilization within the regulation. In addition, there could also be thought of interim mandatory renewable gases, for example a GHG reduction target of 20 % by 2030.
- GBA suggests to refer to the Renewable Energy Directive for certification requirements to keep all consistent: “Renewable gases shall be certified in accordance with Article 29 and 30 of Directive (EU) 2018/2001.”
- There is a largely equal treatment of “low carbon” and renewable gas/hydrogen; this hinders the deployment of renewable energy while promoting fossil/nuclear based energy falling within the threshold (incl. non-renewable hydrogen!). This is a no-go and hinders investments in really sustainable non-fossil and non-nuclear energy. Thus, GBA promotes a clear advantage for renewable gases to lead investments in the right direction. This shall include a separate target for renewable gas (including the accountability of negative-carbon gases) and a clear feed-in priority for renewable gas over low-carbon gas and fossil gas.
- In order to achieve the EUs climate targets, the use of all renewable energy resources and technologies for green hydrogen production, including biogenic, should be possible. As Germany, and the entire EU, would need to import considerable amounts to meet targets, biogenic hydrogen shall be able to take a role in the energy transition. Biogenic hydrogen is not mentioned and not yet defined. However, GBA thinks it necessary to clearly define it and include definitions not only in this regulation but also in the delegated act on hydrogen as well as in the revision of the Renewable Energy Directive.
- There is no clear distinction between fossil-based, low-carbon and renewable gases within the regulation. Renewable gas is no “natural gas” and should always be addressed separately. In the regulation, fossil gas and biogas both fall within the category of “natural gas”. GBA suggest to clearly distinct between renewable gas, low-carbon gas and natural gas and include this in the definitions in Art. 2. The provisions of RED II define the GHG emissions along the production cycle of renewable (i.e., bio-) gases. Their definitions for "advanced fuels", but also for power generation reflect the definitions of negative-, zero- and low-carbon gases.
Read full responseResponse to Revision of Alternative Fuels Infrastructure Directive
18 Nov 2021
In principle, the orientation of the ETD towards climate protection is welcomed, as it puts an end to the preferential treatment of fossil energy sources. However, there are some details to address in more clarity.
1. Definitions of categories
There are no clear definitions within the Directive. The German Biogas Association suggests to merge the categories “sustainable food and feed crop biogas” and “sustainable (but not advanced) biogas”. A distinction between these two categories as proposed by the Commission is not grounded in the Renewable Energy Directive 2018/2001 (RED II) which is the central piece of legislation in this field. Within RED II it is defined that when biogas is sustainably produced from food and feed crops, it complies with the same sustainability criteria and GHG emission savings as any other “sustainable biogas”. Therefore, the categories “sustainable food and feed crop biogas” and “sustainable biogas” should be merged into one. “Sustainable biogas” should be defined as:
“a gaseous fuel produced from other feedstocks than those listed in Annex IX – Part A of the Directive 2018/2001, and complying with the sustainability and GHG emission saving criteria of this Directive, as appropriate”.
2. Set new category at 50%-level till 2033
The proposal of the Commission sets a minimum taxation level for “sustainable food and feed crop biogas” at the same level as fossil fuels in 2033. This is utterly paradoxical with the sustainability requirements of the RED II. Recital (91) of the current RED II upholds that “Feedstock which has low indirect land-use change impacts when used for biofuels, should be promoted for its contribution to the decarbonisation of the economy”. That is why GBA strongly recommends that the re-defined “sustainable (not advanced) biogas”, as proposed above, keeps the second lowest rank of minimum taxation level, namely 50 % taxation level till 2033.
3. Ranking and proportionally distances between the categories – Art. 5(1)
In principle, the orientation of the ETD towards climate protection is welcomed, as it puts an end to the preferential treatment of fossil energy sources. However, it should be clarified whether, in addition to the ranking, the distances between the taxation levels of different energy sources must also be strictly observed. This is relevant in Germany, for example, where tax rates are regularly higher than the minimum tax rates suggested. For a noticeable effect the tax rates in the Member States would have to be adjusted proportionally to the distances between the minimum tax rates per category.
4. Tax reductions and exemptions – Art. 8 & 13
Article 8 and Article 13 allow tax reductions or exemptions by the member states. These facts are important for agricultural enterprises as well as for biogas plants that produce electricity in a CHP plant. If the exemption for energy sources set out in Article 13 were to be abolished, the biogas generated in a CHP plant would have to be taxed by the plant operator. This would mean that the plant could no longer be operated economically, as the payments for the electricity generated are fixed. In addition, this would mean double taxation, as the electricity generated would subsequently have to be taxed in the regular way. The regulations formulated in Article 13 must in any case be retained in the further procedure.
6. Promotion of biogenic hydrogen
Biohydrogen can be made from biogas or through gasification of biomass. While production pathways require more development and testing, this renewable energy could join the renewable gas mix in the long-term. However, it is not recognised today in the EU law or in the new ETD proposed by the Commission, and this could prevent its development. GBA recommends setting a level playing field for all sources of green hydrogen, including biohydrogen from sustainable biomass.
More details in the attachment.
Read full responseResponse to Revision of the Energy Tax Directive
18 Nov 2021
In principle, the orientation of the ETD towards climate protection is welcomed, as it puts an end to the preferential treatment of fossil energy sources. However, there are some details to address in more clarity.
1. Definitions of categories
There are no clear definitions within the Directive. The German Biogas Association suggests to merge the categories “sustainable food and feed crop biogas” and “sustainable (but not advanced) biogas”. A distinction between these two categories as proposed by the Commission is not grounded in the Renewable Energy Directive 2018/2001 (RED II) which is the central piece of legislation in this field. Within RED II it is defined that when biogas is sustainably produced from food and feed crops, it complies with the same sustainability criteria and GHG emission savings as any other “sustainable biogas”. Therefore, the categories “sustainable food and feed crop biogas” and “sustainable biogas” should be merged into one. “Sustainable biogas” should be defined as:
“a gaseous fuel produced from other feedstocks than those listed in Annex IX – Part A of the Directive 2018/2001, and complying with the sustainability and GHG emission saving criteria of this Directive, as appropriate”.
2. Set new category at 50%-level till 2033
The proposal of the Commission sets a minimum taxation level for “sustainable food and feed crop biogas” at the same level as fossil fuels in 2033. This is utterly paradoxical with the sustainability requirements of the RED II. Recital (91) of the current RED II upholds that “Feedstock which has low indirect land-use change impacts when used for biofuels, should be promoted for its contribution to the decarbonisation of the economy”. That is why GBA strongly recommends that the re-defined “sustainable (not advanced) biogas”, as proposed above, keeps the second lowest rank of minimum taxation level, namely 50 % taxation level till 2033.
3. Ranking and proportionally distances between the categories – Art. 5(1)
In principle, the orientation of the ETD towards climate protection is welcomed, as it puts an end to the preferential treatment of fossil energy sources. However, it should be clarified whether, in addition to the ranking, the distances between the taxation levels of different energy sources must also be strictly observed. This is relevant in Germany, for example, where tax rates are regularly higher than the minimum tax rates suggested. For a noticeable effect the tax rates in the Member States would have to be adjusted proportionally to the distances between the minimum tax rates per category.
4. Tax reductions and exemptions – Art. 8 & 13
Article 8 and Article 13 allow tax reductions or exemptions by the member states. These facts are important for agricultural enterprises as well as for biogas plants that produce electricity in a CHP plant. If the exemption for energy sources set out in Article 13 were to be abolished, the biogas generated in a CHP plant would have to be taxed by the plant operator. This would mean that the plant could no longer be operated economically, as the payments for the electricity generated are fixed. In addition, this would mean double taxation, as the electricity generated would subsequently have to be taxed in the regular way. The regulations formulated in Article 13 must in any case be retained in the further procedure.
5. Promotion of biogenic hydrogen
Biohydrogen can be made from biogas or through gasification of biomass. While production pathways require more development and testing, this renewable energy could join the renewable gas mix in the long-term. However, it is not recognised today in the EU law or in the new ETD proposed by the Commission, and this could prevent its development.
GBA recommends setting a level playing field for all sources of green hydrogen, including biohydrogen from sustainable biomass.
More details can be found in the attachment.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
18 Nov 2021
The European Union’s commitment to meeting the Paris climate targets and achieving climate neutrality by 2050 will have to lead to major policy adjustments in the next years. In line with the revision of other key framework legislation in the so-called Fit for 55 Package, the revision of the Renewable Energy Directive (RED III) is of key importance for our common ambition. To reach the climate targets EU member states need to significantly accelerate and increase the volume of all available renewable energies and realise a truly integrated energy system that helps to reduce greenhouse gas emissions in all end-use sectors. BEE therefore welcomes the Commissions initiative to propose an update of the RED and appreciates the opportunity to provide feedback.
Renewable energy deployment must be at the heart of this energy transition and requires seri-ous on-going, flexible, smart, and effective strategic support. must not be limited or focussed on to the electricity, but it must also be significantly intensified in the other sectors. The building and transport sector in particular have enormous potential in that regard and should be strength-ened in EU legislation. Companies all over Europe urgently need planning security over 10 years. This must be taken into account in all adjustments. Changes every two years, as is the case today, or the uncertainty that changes might be imminent, prevent investments and devel-opments. For this reason, an ambitious target for the share of renewable energies should be set now and complemented with strengthened rules for removal of administrative barriers and mitigating investment. Generally, we still think that low carbon fuels of fossil origin do not fit in a Renewable Energy Directive and should be removed.
From the perspective of the renewable energy sector, adjustments should be made in particular to the following articles:
- Article 3 Paragraph 1
- Article 3 Paragraph 3
- Article 4
- Article 15a
- Article 16
- Article 19
- Article 22a
- Article 23
- Article 24
- Article 25
- Article 26
- Article 29, paragraph 1
- Article 29, paragraph 3-5
- Article 29, paragraph 10
- Article 31
Please find attached our complete statement with detailed comments on the individual articles of the amended Renewable Energies Directive.
Read full responseMeeting with Markus Pieper (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and
9 Nov 2021 · RED III
Response to Revision of the CO2 emission standards for cars and vans
8 Nov 2021
The proposal's main focus is set towards the "CO2 emission standards for passenger cars and light commercial vehicles" by "boosting the uptake of zero emission vehicles and related infrastructure" [p. 2]. In general, the German Biogas Association supports this approach, especially since at first sight "decarbonisation" of electricity production and renewable as well as low-carbon fuels shall be supported. The German Biogas Association welcomes the revision but sees two issues that must be addressed:
1. Establishing Well-to-Wheel-Approach as Standard
On page 4, it is written:
"The CO2 emission standards, supplying new zero-emission vehicles to the market,[...] which will decarbonise the production of electricity used in electric vehicles and incentivise the uptake of renewable and low carbon fuels for the combustion engine vehicles in the stock. [...]
...will drive decarbonisation of the power generation, so that zero-emission vehicles, incentivised by the CO2 emission standards, are progressively powered by renewable energy sources thus achieving decarbonisation of full well-to-wheel emissions." [p. 4]
The German Biogas Association strongly supports the "well-to-wheel" approach for all technologies. However – taking the current energy mix (EU- or nation-wide) into consideration, neither hydrogen fuel cells nor batteries are yet "zero-emission”. In accordance with the provisions of the current Renewable Energy Directive and the ongoing revision (RED II / RED III), already today, zero and even negative GHG emissions can be achieved also with biofuels if residues like manure are utilized. With gas grids and rising numbers of gas stations, a functioning infrastructure is available – taking into consideration that natural gas grids could transport 100 % of biomethane. A true "well-to-wheel approach" as it is defined for biofuels from cultivation, production, transport and emission avoidance should therefore also be considered for electromobility taking into account the type of electricity used and all production steps and disposal of e. g. batteries after their end of life as well as for the hydrogen value chain, in order to create a level-playing-field for all renewable energy.
2. Negative GHG emissions
Chapter 3 [p. 6] thematises new obligations not yet fully in force:
"[...] This concerns, in particular, the new 2025 and 2030 EU fleet-wide targets and the incentive mechanism for zero- and low-emission vehicles. However, a revision is necessary in order to bring the Regulation in line with the ambitions of the European Green Deal, […]".
In general, the German Biogas Association welcomes a revision of the fleet targets, now taking biofuels into consideration. However, the proposal states on p. 11:
"A sub-paragraph is added to paragraph 1 of Article 4, in which a safeguard is introduced to avoid that the calculation of the manufacturer’s specific emission targets under certain conditions would result in a negative target. Where that situation would occur, the specific emission target should be set to 0 g CO2/km."
Taking the provisions of the RED II into account, measures are taken that with some feedstock types for biomethane generation, negative GHG emissions are accountable. This is particularly true for wet manure (see Directive (EU) 2018/2001, p. 99, p.111, p. 123). Thus, this stipulation of setting the target at 0 g CO2 / km does not make sense. Either there is a calculations methodology that assesses all emissions or not. Since there is within the RED, it does not make sense to disadvantage biofuels by choosing 0. In German Biogas Association’s opinion, an alignment with the RED and the CVD (Clean Vehicle Directive) is necessary. Therefore, we suggest to transfer the provisions of the Renewable Energy Directive into the CVD in order to make the "Fit for 55 package" and its regulation documents consistent.
Read full responseMeeting with Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)
28 Oct 2021 · Draft State aid Guidelines on Climate, environmental protection and Energy
Response to Climate change mitigation and adaptation taxonomy
18 Dec 2020
The German Biogas Association (GBA) welcomes the efforts of the European Commission to differentiate between sustainable and non-sustainable investments through the draft delegated act on taxonomy. However, the draft of the delegated act raises doubts as to the seriousness of the intentions.
For one, ANNEX 1 and 2 comprises several chapters regarding bioenergy as well as energy in transport and manufacturing of cars. However, in the Technical Expert Group there is no representative of this group. In addition, there are several conditions regarding agricultural system – in the Expert Group, however, a representative of the agricultural sector is missing. This unbalanced approach to Export Group Composition is reflected in the draft regarding its regulations to agricultural systems, car manufacturing and bioenergy.
In view of more ambitious goals for greenhouse gas emissions reduction the EU Commission should promote all technologies possible to defossilize the European economy. For this, we need all options – electric as well as hydrogen and biofuels and power to gas. Bioenergy, especially biogas, can play a significant role in reducing greenhouse gas emissions as well as offer solutions for waste and residue management. In addition, it can contribute to enhancing biodiversity and soil protection. Thus, we strongly urge the EU Commission to amend the draft accordingly and to compose Technical Expert Committees with all experts needed in the respective area in future.
The more detailed feedback can be found in the attachment.
Read full responseResponse to Revision of the Energy and Environmental Aid Guidelines (EEAG)
10 Dec 2020
I. Define Renewable Energies as matters of “public interest”
Given the urgency of mitigating the climate crisis in line with the Paris Agreement, the construction of renewable energy facilities and projects and support mechanisms should be defined as matters of “public interest” from now on. It is therefore necessary that most of these support mechanisms designed in the public interest get more leeway under state aid guidelines, thus accelerating the deployment of renewable energies, serving an enormous amount of time, and guaranteeing the security of investments which is crucial for investors.
II. Considering the diversity of actors
Small and Medium-sized energy producers, Cooperatives and Community Energy need appropriate regulation and support. Local opposition to RES projects has a serious impact on RES development. The encouragement of citizen participation in and ownership of renewable energy projects is crucial, as it will lead to an overall increase in public support for these projects. Therefore, barriers such as inadequate design of the de minimis regulation for mandatory auctioning, (market) premiums and feed-in tariffs should be revised.
III. Creating the right framework for market integration of renewables
The currently installed capacities do not generate more electricity than demand. State aid guidelines that influence the production and feed-in behavior of system operators due to developments in the electricity market (such as Section 124 of the current EEAGs) must take this into account.
IV. Bringing forward support schemes for integrated renewable energy projects including system services
Support schemes have emerged which provide aid to projects that combine a number of individual installations and/or technologies, which jointly can significantly secure and enhance the system transformation by providing security of supply, including auxiliary, balancing and other system services. Good practice examples of such integrated projects/packages and their support should be promoted in order to encourage these highly beneficial initiatives EU-wide.
V. Technology-specific auctions must be maintained
Each technology has its own characteristic in terms of performance for the power system beyond the criteria of energy as system services and capacity guarantee. Technology neutral tenders are not able to deal with these requirements for system stability.
Please find full details of our recommendations in the attached document.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
The German Biogas Association welcomes the EU's ambition to revise the Renewable Energy Directive's goals. The German Biogas Association thinks it very necessary to align the different legislative acts and thus votes for option 5. Binding targets are needed in order to accelerate the greenhouse gas emissions reduction and to ensure that renewable energy is deployed across all sectors throughout Europe.
For the German Biogas Association it is vital to increase the renewable energy target as well as the subtargets within the transport sector substantially. In addition, the goal in the heat and cold sector should be binding to have an effect.
Besides, calculating greenhouse gas balances to show the sustainability of renewable fuels is vital and should be extended to all renewable and fossil fuels (as reference values) - no matter which technology is addressed. This also includes hydrogen and electricity.
In order to de-fossilize all sectors as fast as possible, the German Biogas Association calls for:
• A binding renewable gas target in the final gas consumption in the EU by 2030
• A binding quota to increase the share of renewable energy in the heating and cooling sector as an annual average calculated for the periods 2021 to 2025 and 2026 to 2030.
• A higher Renewable Energy Goal of 45 %
• A higher goal within the transport sector for renewable fuels of at least 20 % and an increase in the sub-quota
• Taking into account specific synergies like increasing biodiversity through wild plant mixtures and decreasing soil erosion trough flowering perennials like Silphium Perfoliatum via an extension of ANNEX IX of the Renewable Energy Directive with these feedstocks that can be used to generate biogas after flowering.
• Extending the existing greenhouse gas calculation methodology to all renewables and fossil fuels, including electricity-based fuels, hydrogen and shale gas / oil as reference value to ensure technology-neutrality
• Include further GHG emissions savings default values for a number of biogas feedstocks (like straw, grassy energy crops, wild plant mixtures, Silphium Perfoliatum and ley and cover crops)
• Removing the multipliers for biofuels and lower the multiplier for electricity (not more than 2.5)
The German Biogas Association, however, is also worried about the re-opening of the directive if that means another year or more time of negotiations. We therefore suggest to implement RED II as foreseen till 2021 in the Member States and add changing conditions later on. Alternatively, the ANNEXES V and IX could be implemented as new basis of calculation methodology for greenhouse gas calculations as soon as possible and replace to existing rules.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
21 Sept 2020
The German Renewable Energy Federation (BEE) welcomes the COM proposal to reduce GHG emissions by at least 55 percent by 2030. In order to be able to achieve an ambitious greenhouse gas reduction target of at least 55 percent by 2030 compared to 1990, an equally ambitious increase in the targets for the share of renewable energies in gross final energy consumption and energy efficiency are necessary. When revising the Directive (EU) 2018/2002 the Commission should consider that there are numerous calls for at least 60 up to 65% greenhouse gas emission reductions, including from the EP’s ENVI (asking for an at least 60% reduction target). Therefore, for Europe’s 2030 climate ambition we agree, that the existing target for energy efficiency of 32.5 % by 2030 needs to be increased. Given the analysis laid out in the impact assessment the increase should be in the order of magnitude of at least 40% instead.
The overall strategy to reduce energy consumption and reach climate neutrality should focus on expanding the use of renewable energies as primary energy source, because the reduction of carbon emissions by the use of renewable energies such wind and solar or biomass is increasingly cheap. When revising EED the role of innovative technologies like heatpumps or solarthermal applications should certainly be strengthened. To tap the full cost-effective potential of these efficient technologies renewable energies, need to be promoted.
In order to support the use of these efficient energies and technologies, a mix of measures is needed. This consists of corresponding price signals (high minimum price for CO2), regulatory frameworks and attractive funding. To reduce the final energy consumption a dynamic expansion of renewable energies, especially in the building sector is required.
Furthermore, the revision should implement binding targets and milestones for the share of energy efficiency in all sectors to underpin the reduction of GHG-emissions. Such goals and milestones must be set both for the European level and for each Member States in order to achieve the commissions goal to reduce GHG emissions by at least 55 percent by 2030. But the revision must also respect the subsidiarity principle as well as the Member States’ right to choose their own energy mix. It must strike the balance between mandatory target achieve-ment and flexibility for member states in choosing their preferred mix of renewable energy, energy efficiency and energy savings.
The increase of energy efficiency through renewable energies must also be tapped more intensively in the other sectors. The transport sector in particular has enormous potential in that regard. The expansion of renewable energies in these sectors would also contribute to increased sector coupling and thus to an increase of energy efficiency and the resilience of the energy system.
Read full responseResponse to Long term vision for rural areas
9 Sept 2020
We welcome the EU's intention to develop a long-term vision for rural areas. Biogas can help to stabilize income in rural areas, to held added value in the region and to help in fighting climate cchange at the same time. As you see in the attached paper, with biogas it is possible to bring together environmental protection and agriculture. Biogas not only contributes to the avoidance of methane emissions from manure while offering farmers an additional income, the versatility of usage of many different feedstocks also allow for many that help to promote biodiversity. For instance wild mixed plants planted for insects and enhancing biodiversity can be fermented in biogas plants. But also other perennial plants like Silphium Perfoliatum or energy grasses can be fermented in biogas plants thus lowering the cost for such environmentaly advantageous programmes. Therefore, the German Biogas Association asks the EU to consider bioogas in any long-term vision for rural areas.
Read full responseResponse to EU Methane Strategy
23 Jul 2020
The German Biogas Association (FvB) welcomes the EU Commission’s goal to reduce methane emissions. For this, FvB suggest the following steps:
- Fossil fuel extraction: In the new Directive (EU) 2018/2001 - Renewable Energy Directive (RED II) a methodology is laid down how to calculate life cycle assessments of biofuels. Within this well-to-wheel approach methane emissions are also covered. However, the fossil fuel comparators are quite uniform and do not reflect the currently existing different gas extraction methods in different countries. In order to have actual up-to-date emission from fossil fuel extraction and transportation, all greenhouse gas emissions along the whole life cycle should be recorded and updated. Within that, there should be a distinction of fossil fuel extraction between conventionally won gas /oil and fracking gas / oil or – alternatively -a higher fossil fuel comparator should be chosen that reflects the different shares of the different gas extraction methods. Up to now, no such distinction is made.
- Mobilization of waste and manure collection: In order to avoid uncontrolled emissions of methane, landfill and sewage gas should be utilized in respective plants to produce methane. More incentives should be given to utilize manure in biogas plants. In Germany, only 25 % of the available manure is utilized in biogas plants. This share could be increased up to at least 60 % if certain measures are taken (see also attachment, in German). A hydraulic retention time of 150 days or a continuous survey of the digestate’s residual gas potential reduces methane emissions enormously. To increase the value of the manure utilization, the roll-out of small digestors under 150 kW el and 100 m³/h biomethane production capacity must be supported.
- Avoidance of methane slip at biogas plants or biomethane upgrading units: In Germany, methane slip at biogas plants or at upgrading units was drastically reduced in the last ten years. There are several legal requirements (44. BImSchV, TRAS 120, TRGS 529, TA-Luft, DGUV R-113-001 etc.) that set thresholds for methane slip within biogas production, the use in CHP as well as within upgrading units (Renewable Energy Sources Act, Gas Network Access Regulation). In addition, there are several requirements as to how input material is stored and feeded, how digestate is stored, how biogas leading components have to be constructed and maintained, how gas collector membranes are made/monitored and as to how well CHPs comply with methane slip limits etc. All this can lower methane slip significantly. Within the EvEmBi-project (Evaluation and reduction of methane emissions from different European biogas plant concepts) a range of options for reducing methane emissions is currently examined.
The German Biogas Association sees great methane avoidance potential in biogas production, not only with further utilization of waste and manure but also with the current technical standards. However, running a biogas plant must still be economical – so in order to fulfill new requirements there must be enough support to boost biogas plant construction and offer economic perspectives.
Read full responseResponse to Sustainable and Smart Mobility Strategy
20 Jul 2020
The German Biogas Association welcomes the effort of the EU Commission to tackle the transport sector emissions and to establish a sustainable and smart mobility strategy. The most important thing is to act fast and to lower the carbon emissions from the transport sector as soon as possible. For this, all kind of renewable fuels and alternative drives should be implemented. Until now, there has been a strong focus on electric drives only. However, the achievement of environmental goals in the mobility sector requires the usage of all available technologies to replace fossil fuels quickly. Biomethane as a carbon-neutral fuel should be promoted more actively, as it is the only currently commercially available option to substitute fossil fuels in the heavy and long-distance transport. Besides, biomethane has a strong potential in the water transport. Through its undoubted environmental benefits biomethane can help increasing biodiversity, soil health and promoting resource efficiency by using new feedstocks like wild plant mixtures or other perennial cultures. Both combine energy production with the provision of eco-system services and perennial soil cover. In addition, the use of mineral fertilizers is minimized and local jobs in rural areas are stimulated.
The German Biogas Association recommends the following strategies that needed to be implemented urgently:
• The carbon reduction potential of bio-CNG and bio-LNG, along other alternative fuels must be recognized and promoted.
• A target for biomethane use in transport by 2030 should be set.
• As foreseen in RED II for biofuels, there should be support for well-to-wheel or LCA (Life Cycle Assessment) approaches by 2030 in all transport and fuel related legislation to guarantee the accurate and comprehensive quantification of carbon emissions in the transport sector. The methodology must be the same for all fuels and drives and all kind of fuels should be subjected to respective sustainability proof over the whole life cycle, also hydrogen and electricity and all fossil fuels.
• As long as these approaches are not established for all fuels, biomethane should also be recognized as a non-carbon contributor, on equal footing as electric mobility. This could be set in the context of the revised Energy Taxation Directive and Fuel Quality Directive, as well as the Regulation setting carbon emission performance standards for new passenger cars and for new light and heavy duty vehicles.
• Biomethane should also be promoted as green fuel in the Alternative Fuels Infrastructure Directive (AFID) and as zero-emission fuel in the Clean Vehicles Directive.
• EU car manufacturers should be encouraged to develop and produce the required clean fuel gas engines that will enable the scale-up of biomethane in the transport sector.
Read full responseResponse to Commission Communication – "Renovation wave" initiative for the building sector
3 Jun 2020
BEE fully supports the EU EC’s perspective that buildings are indispensable for achieving carbon neutrality by 2050. BEE, however, emphasizes that the renovation wave should not be limited to energy efficiency measures as renewable heating applications allow low-cost decarbonisation. BEE agrees that current renovation rates across Europe are insufficient for massive reductions of GHG emissions. As building renovations are capital-intensive and long-term in nature, a strategic approach is needed to mobilize the market and to tackle existing barriers.
The listing of different barriers in the EC’s roadmap illustrates the multi-dimensional complexity of building renovations. In order to accelerate the use of renewables for heating (and cooling) a particular focus of the renovation wave should be put on existing barriers to a rapid uptake. Obviously, the full range of renewable heating applications - heat pumps, biomass CHP/boilers, solarthermal and geothermal applications etc. - will be needed to cover the energy demand of the sector towards 2050. Therefore, a massive acceleration of aforemen-tioned technologies‘ installation rates is needed. BEE suggests an in-depth investigation of existing barriers to achieving this goal. Such investigation must address the market conditions on EU level for technologies based on renewable energies. We see two major barriers which must be addressed by a renovation wave initiative in line with the goal of climate neutrality. First, still existing direct and indirect subsidies for fossil energy delay or even prevent the installation of technologies based on renewable energies in the heating and building sector. Effective carbon pricing and implementing the polluter-pays principle would facilitate a much faster uptake and effective and efficient integration of different renewable energy technologies in the heating, cooling and building sector. Financially rewarding or supporting fossil and nuclear energy while in parallel supporting increased use of renewable energies at the same time should definitely be avoided. It is necessary to evaluate any policy measures beforehand on whether the impact would lead to fossil fuel lock-in for heating and cooling and in the building sector in general.
Secondly effective funding programmes to stimulate the use of renewable energy-based technologies are needed on EU level and on national, regional and local level. The renovation wave initiative should address the implementation of such programmes. The German “Market Incentive Programme” (MAP) is a proven tool to help individuals, companies and municipalities to trigger the necessary investments in the building sector. Thus, the renovation wave should develop a similarly effective tool coordinating national and sub-national programmes and where appropriate establish supporting measures on EU level.
BEE welcomes the application of the subsidiarity principle for the renovation wave. The complexity of housing renovation requires a joint effort on all governance levels. Noteworthy, housing renovation and the production of renewable heat or cold is typically marked by local conditions. As local authorities are most familiar with local conditions, a continuous and target-oriented exchange between authorities on different levels seems to be promising. We welcome the ambitious goal of the imitative to increase renovation rates across Europe and to substantially decrease GHG emissions in the building sector. A strategic approach is necessary; an action plan with concrete measures to address main barriers and to reinforce the pull factors for faster and deeper renovation is certainly a promising approach. Consultations should be held on a regular basis and therefore allow all interested stakeholders and social groups to participate and express their views. The EC should encourage local authorities in their moderating roles to promote energetic renovations of neighbourhoods and districts.
Read full responseResponse to Climate Law
30 Apr 2020
The German Renewable Energy Federation (BEE) welcomes the European Commission’s proposal for a European Climate Law as part of the “European Green Deal”. In this context we value the proposal that all legislative proposals should be subject to a “Climate Consistency Assessment” in order to evaluate their conformity with the goal of greenhouse gas neutrality.
However, the proposal lacks ambitious GHG reduction targets for the years 2030 and 2040. Numerous studies show that earlier and more ambitious greenhouse gas reductions are more effective and less costly . The intention to start the discussion about a higher target for 2030 in the range of 50-55% GHG reduction in autumn and to finally decide only in 2021 leads to urgent decisions being postponed too far into the future. We welcome the proposal to authorize the Commission to define more ambitious reduction targets by delegated acts after 2030, if this turns out to be necessary for reaching the overall emission reductions targets. In order to achieve the goals of the Paris Agreement it will most likely be necessary to apply this mecha-nism; therefore, it is important to ensure that it is maintained during the legislative process. Furthermore, the Commission should consider that based on numerous studies, there are already calls for a 65 percent reduction. The proposal does not only lack clear milestones and reduction targets, but also binding targets and milestones for the share of renewable energies in all sectors to underpin the reduction of GHG-emissions. Such goals and milestones must be set both for the European level and for each Member States in order to achieve the necessary full decarbonization. Furthermore, simply setting an undefined target in the future is not enough. It is very important to consider EU-wide remaining carbon budgets and not to exceed them. However, a clearly defined carbon budget remaining for the EU in terms of global climate justice and in line with the 1.5° C target is not part of the proposal.
Unfortunately, the proposal also remains unclear regarding the necessary phase-out from fossil fuels and the change to a system of flexible, decentralized, clean and sustainable renewable energies. The proposal lacks the clear objective of phasing out all remaining direct and indirect subsidies for fossil fuels and a complete phase out of fossil fuel use by 2050 at the latest. Under no circumstances there should be any measures to promote technologies of capture, storage or processing and use of greenhouse gases, for example in the form of CCS or CCU, besides for the compensation of unavoidable CO2 emissions, because they would help to preserve the fossil economy. The EU must legally require that by 2050 no fossil fuels can be used for energy generation. An energy system based on 100 percent renewable energies must be established by 2050 at the latest.
The law must respect the subsidiarity principle as well as the Member States’ right to choose their own energy mix. It must strike the balance between mandatory target achievement and flexibility for member states in choosing their preferred mix of renewable energy, energy efficiency and energy savings. The Commission's proposal is based on the National Energy and Climate Plans (NECPs) provided for in the Governance Regulation. We welcome the planned evaluation of these plans in terms of compatibility and suitability with the objectives of the European Climate Law. Member States should be required to present and regularly update their National Energy and Climate Plans (NECPs).
Finally, therefore, the proposal in its current form does not yet provide an appropriate legal framework for achieving the goals of the Paris Agreement and the decarbonization of the European continent in all sectors.
Read full responseResponse to 2030 Climate Target Plan
14 Apr 2020
First of all the German Renewable Energy Federation (BEE) wants to point out that the Commissions’ plan, to define a reduction target for the year 2030 after a review of the requirements set out in Article 2 (11) of Regulation (EU) 2018/1999 by September 2020, leads to urgent decisions being postponed too far into the future and chances in the area of economic growth not being used. Moreover, it will increase long-term costs for climate protection and achieving the targets of the Paris Agreement. We underline that it is essential to establish a linear trajectory with binding milestones for GHG-reduction to achieve climate neutrality by 2050. Building on these necessities it is necessary to discuss and establish a clear and ambitious target in the context of the climate target plan 2030.
Numerous studies show that earlier and more ambitious greenhouse gas reductions are more effective and less costly. A binding target of at least 55% GHG-reduction by 2030 is therefore necessary to ensure cost-effective action. A higher target of 65 % as called for by NGOs should be considered by the Commission to give stronger incentives to the European industry. The 2030 climate target plan should be monitored on a regular basis with the option of increasing ambition. Where lack of ambition or lack of enabling frameworks or inconsistencies with other legislation are found, additional measures need to be required.
Moreover, the 2030 climate target plan must build on scientific evidence, which underlines the limited remaining carbon budget to stay within the planetary boundaries and thus achieve the targets of the Paris Agreement. The climate target plan must break down this remaining carbon budget for each Member State and each sector. It is very important to understand that the concrete reduction target for the EU as a whole can only be achieved by 2030 with fair and mandatory contributions from each Member State.
In the context of the climate target plan 2030 this means that such goals and milestones must be set both for the European level and for each Member State in order to achieve the necessary decarbonization by 2050. Defining the GHG-reduction target 2030 merely as a collective objective with reporting requirements for the Member States will not be enough to ensure climate neutrality by 2050. Building on existing legislation the greenhouse gas reduction target should be underpinned by appropriate sectorial trajectories, milestones and targets for the share of renewable energy and for energy efficiency increase, on EU level and for each Member State. Of course, the climate target plan will have to be in line with the subsidiarity principle as well as the Member States’ right to choose their own energy mix. It must therefore strike the balance between mandatory target achievement and flexibility for Member States in choosing their preferred mix of renewable energy, energy efficiency and energy savings.
The climate target plan should aim at avoiding emissions rather than suggesting their later removal (and use and/or storage) to trigger the most cost-efficient pathway towards a GHG-reduction of at least 55% by 2030 and to full decarbonisation by 2050 the very latest. An energy system based on renewable energy sources such as wind, solar, biomass, hydropower and geothermal sources must be the method of choice to achieve GHG-reduction together with environmental and social compatibility.
Read full responseResponse to Climate Law
6 Feb 2020
The German Biogas association (FvB) welcomes the European Commission’s (EC) initiative for a European Climate Law to legally establish the objective of climate neutrality by 2050 and to provide rules to ensure that all policies of the EU institutions and of the EU Member States (MS) contribute to such a goal.
The climate law must define climate neutrality clearly. This definition should be built on scientific evidence, it must be ensured that the remaining carbon budget will stay within the boundaries set by the Paris Agreement. It should also make it clear that fossil fuels will only have a function in a transition period but will be phased out as soon as possible. In order to achieve the set climate goals it may be necessary to use CCS / CCU – however, such measures should only be considered in addition to a fully renewable energy system and should by no means be used to prolong the use of fossil fuels sources. Thus, implementing policies are needed in order to remove the remaining barriers for increased energy efficiency and accelerated deployment of renewable energy across all end-use sectors. This will trigger the most cost-efficient pathway towards decarbonisation, and it will help avoid trillions of Euros of stranded investment, which would be inevitable, if investment in fossil resources were not quickly reduced and finally phased out.
The climate law must ensure that target achievement is mandatory and that MS are still flexible in choosing their preferred mix of renewable energy, energy efficiency and energy savings within a fully renewable energy system. Ruling out support for any fossil-fuel-based technologies should be included in the law in order to set a fair market for all other technologies. A carbon floor price within a strong and functioning ETS would ensure that investments will be directed in the right direction. In order to achieve climate neutrality by 2050 all renewable sources should be able to contribute to the goal. No technology option should be preferred but countries should be able to use a broad mix of options adapted to their respective needs. In order to minimize costs, technologies that are cheap and already available should be exploited fully before implementing more expensive technologies.
The law should establish the objective of climate neutrality by 2050 at the very latest to be achieved by the EU as a whole with fair and mandatory contributions from each MS. The contributions of the MS should be legally binding. To be effective, the law must encompass the ultimate objective of climate neutrality as well as a linear trajectory with binding milestones for 2030, 2040, 2050. Shorter intervals of 5 years could be considered. The milestone for 2030 should be at least 55% GHG reduction (considering proposals of 65% as desirable). In 2040, at least 75-80% should be achieved. Trajectory and milestones should be monitored on a regular basis with the option of increasing ambition. Where lack of ambition or lack of enabling frameworks or inconsistencies with other legislation are found, additional measures need to be required. Following the Governance Regulation (with some necessary amendments) MS should be required to present and regularly update National Climate and Energy Plans (NECPs). Once established and accepted by the EC, the full implementation of these NECPs – which should be closely linked to the NDCs submitted under the Paris Agreement – should become mandatory and subject to infringement procedures and penalties.
The climate law is only a first step towards a European Green Deal encompassing all sectors and achieving climate neutrality well before 2050. To drive ambitious and effective decarbonisation of Europe’s economy, existing legislation on energy taxation, emissions trading, renewable energy, energy efficiency, building standards, fuel quality, sustainable mobility, and just transition will have to be adjusted within the next three years.
Read full responseMeeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)
5 Oct 2016 · Renewable Energies
Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete), Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)
29 Apr 2016 · Electricity market design and renewables policy
Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)
11 Feb 2016 · Energy Union
Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)
16 Dec 2015 · governance of the Energy Union and upcoming initiatives to implement the Energy Union Strategy
Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)
16 Nov 2015 · Energy Union governance
Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)
16 Jun 2015 · Energy Union
Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)
2 Jun 2015 · The development of a reliable and transparent Energy Union governance framework, including on the relevant European targets contained in the 2030 Energy and Climate package
Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete), Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete) and European Renewable Energies Federation asbl
29 Apr 2015 · Proposals on renewable energy pursuant to the Energy Union Strategy
Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)
29 Jan 2015 · Energy Union and Investment Plan
Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)
3 Dec 2014 · Renewables energy
Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)
2 Dec 2014 · Discussion on Renewable Energy