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Svenska Bioenergiföreningen

SVEBIO

Svebios mål är att utveckla ett hållbart och 100 procent förnybart energisystem där bioenergi används på ett ekonomiskt och miljömässigt hållbart sätt.

Lobbying Activity

Response to Guidance on accelerating permitting processes for renewable energy projects and facilitating Power Purchase Agreements

27 Jul 2022

When defining renewables ”go-to-areas”, all relevant renewable energy sources must be included, and bioenergy cannot be excluded. Bioenergy already today accounts for around 60 percent of renewable energy in EU and the potential for increased use of bioenergy is large. To substantially increase the share of renewable energy in EU, bioenergy must play a major role. Bioenergy can substitute fossil energy in all sectors and thereby reduce increase the security of supply and reduce the dependence on imported fossil fuels in EU in a cost-efficient manner. As bioenergy applications are well-known they can reduce energy shortage in the short term. Bioenergy is unique, as it can offer both solid, gaseous and liquid fuels and substitute all kinds of fossil fuels used on the energy market. Bioenergy can be used to produce both heat, electricity and transport fuels. The member states should define “go-to-areas” where more biomass for energy can be produced, like areas with potentials for increased use of harvest residues from forestry and agricultural, and regions for increased production of energy crops, both dedicated energy crops for biofuels and cellulosic crops like short rotation coppice crops and grassy crops. Potentials for increased use of waste-to-energy should also be identified. Bioenergy has clear advantages in a renewable energy system and can be used both for base-load energy production and as a flexible energy source for balancing and top-load production, when variable renewable energy sources like wind and solar do not suffice. Solid, gaseous and liquid biofuels store energy that can be used when needed. Increased use of bioenergy will also be needed for negative emissions to reduce carbon dioxide levels in the atmosphere, both from large-scale biomass combustion and from fermentation in ethanol and biogas plants. The European Commission must change its negative attitudes and policies related to bioenergy and include bioenergy in all proposals for renewable energy.
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Response to Carbon Removal Certification

2 May 2022

Carbon removal technologies are necessary to reach ambitious EU climate targets with carbon neutrality by 2050. Most climate models that can reach the target in the Paris agreement to limit global warming to 1.5°C above pre-industrial levels include deployment of negative emissions technologies. Among these technologies, BECCS (bio-CCS) is of utmost importance. BECCS has potential to offer large volumes of negative emissions at reasonable cost. The storage is permanent, and the technologies for BECCS are known and demonstrated. In Sweden alone, we have calculated that BECCS could sequester more than 30 million tons of biogenic CO2 annually, at biomass and waste fueled CHP:s, pulp mills, ethanol and biogas plants. This is more than half of the current GHG emissions in Sweden. Besides these negative emissions, also other carbon removal solutions can be used, but they will give much smaller contributions in our country than BECCS. For BECCS to be available and for these large negative emissions to occur, a precondition is large-scale deployment of bioenergy both from forests and from agriculture, as well as waste-to-energy solutions. Bioenergy and negative emissions are closely linked together, two sides of the same coin. Other industrial negative emissions technologies are more expensive and less developed. The lowest cost for increased carbon uptake from the atmosphere can be reached by better use of the natural systems in agriculture and forestry, especially by improved methods to increase yields and growth. The renewable materials and bioenergy can substitute fossil fuels and reduce emissions of fossil carbon. Negative emissions technologies must not be an alternative to emissions reductions from fossil fuel combustion. Strong incentives for reduction of fossil fuel emissions must still be the major climate instrument for EU, like carbon taxes and emission trading. It is important that BECCS is broadly introduced in the coming years. It is therefore essential to introduce a robust certification scheme as a basis for incentives. The cost for the negative emissions will have to be paid by the emitters of fossil carbon and not by the tax payers or governments. This can be done by linking the negative emissions to ETS, and/or with a separate system. Certification can also be a basis for global trade in carbon offsets. Carbon removals from industrial schemes like BECCS and direct air capture, where permanent storage can be proven, should not be mixed with carbon removals of lesser or uncertain permanence. Yet, both types of carbon removal may be needed.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Nov 2021

We support increasing the target for renewable energy from 32 to 40%, but believe that it could be raised further, to 50% in 2030 if the target for the transport sector is raised, which is possible if the attitude towards biofuels from agricultural crops is changed and restrictions on these biofuels are removed. The target for the transport sector of 13% greenhouse gas reduction is too low. This target should be at least doubled, which would be possible with increased use of both conventional and advanced biofuels. No more intermediate targets need to be introduced in addition to the total renewable target and the target in the transport sector. Other targets and guidelines should be indicative. The transition from fossil energy to renewable energy should primarily be promoted with general incentives like carbon taxation and emissions trading. The one-sided focus on electrification and hydrogen is unjustified and contrary to the principle of technology neutrality. Basing the evaluation of vehicles on emissions from the exhaust pipe (zero tailpipe) must be replaced with evaluation of the total environmental impact according to LCA (well-to-wheels). Maximum shares and other restrictions on biofuels from agricultural crops should be removed, and Member States should be allowed to decide whether they want to use available resources in agriculture for the cultivation of energy crops with no limitations from EU level. We support the proposal to abolish double counting of certain fuels and electricity, and this principle should be fully implemented for all types of energy, all raw materials and all sectors. We support the proposal to increase the biodiesel share in diesel from 7% to 10%. Initiatives should also be taken to increase the blend of ethanol in standard petrol from 10% to 15% or even 20%. The sustainability criteria for biomass from forests should not be changed now. They criteria agreed on in RED II have not yet been implemented on the market, and these criteria should first be evaluated before further criteria are introduced. The model with risk assessment in relation to existing forest and environmental legislation works well and provides low administrative costs. The proposed changes impair the competitiveness of forest-based bioenergy, which leads to negative climate effects. The proposal that even smaller biomass users, down to 5 MW, should report creates additional administrative burden and costs, which particularly affect small and medium-sized businesses. The GHG savings criteria for all existing plants is retroactive legislation that can force the decommissioning of well-functioning plants with climate benefits and, in the worst case, lead to return to use of fossil fuels. The proposal to stop support to electricity only plants using biomass will make it more difficult to use bioenergy for flexibility services (balancing power, local capacity). We reject the proposal in Article 3 (3) that the member states should regulate the use of biomass for energy and that the EU Commission would specify such restrictions in 2026. Commodity regulation of the type proposed creates disturbances in the market and uncertain investment conditions. The measure is contrary to the EU's fundamental principles of free competition. We attach a report from Svebio about the disadvantages on restrictions for stemwood use. The negative effects of cascading regulation in Sweden on the wood market is described on page 15 in this report from IEA Bioenergy: https://task40.ieabioenergy.com/wp-content/uploads/sites/6/2013/09/t40-cascading-2016.pdf Proposals to regulate the use of biomass from "plantation forests", to minimize "large felling", not to harvest stumps, etc., entail restrictions on forest management, and infringe on national decision-making power over forest policy. This kind of detailed regulation is contrary to the principle of subsidiarity. We attach a paper on the Swedish scientific research on stump harvest.
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Response to Revision of the Energy Tax Directive

15 Nov 2021

The European Commission misses the opportunity to introduce a common minimum tax rate for carbon dioxide emissions. This is remarkable given that the proposed directive is part of the Green deal. Our proposal is a minimum carbon dioxide tax of 25 €/ton CO2 for all sectors outside ETS. This would be a better incentive than the proposed ETS-system for buildings and transport. The proposals, together with the proposals submitted for the ETS and a new ETS system for buildings and transport, will lead to very different prices for carbon dioxide emissions in different sectors. This results in a cost-inefficient climate policy. We reject the proposal to introduce minimum taxes on biofuels and biomass from wood. No motivation is given for this taxation and it is contrary to the principle that climate-neutral energy sources should not be taxed. It will make it more difficult to achieve ambitious climate targets, resulting in higher GHG emissions than necessary. It is also a negative signal to all enterprises ready to switch from fossil fuels to renewable fuels. The proposal to levy this tax only on wood fuels used in installations above 5 MW will create dual fuel markets and stimulate tax fraud. We reject the proposal for minimum taxes on biofuels with the same argument as for solid biofuels. Biofuels are renewable and carbon neutral and must be considered to have zero emissions at combustion in accordance with international climate conventions. Emissions during the life cycle must be taxed in the sector where they occur, for example in the transport sector for transports of feedstock, or in the manufacture of fertilizers in the chemical industry. The Commission's proposal is that biofuels produced from "food and feed crops", such as Swedish wheat ethanol and Swedish rapeseed diesel RME, should be subject to a minimum tax which from 2023 is half the tax on fossil biofuels and in 2033 will be the same as for fossil fuels. During the period 2023 - 2033, the tax will be gradually raised to the higher level by one tenth a year. The tax will drive these fuels off the market. The Commission does not state a reason for this penalty taxation and it should be rejected. There is no reason to penalize fuels that contribute to reducing fossil carbon dioxide emissions in the transport sector. The same applies to the penalty tax that is proposed for "sustainable biogas" and for "sustainable biofuels" in general. For these fuels, a tax is proposed that is half of that on fossil fuels in 2023, but without an increase until 2033. It is particularly difficult to understand the logic of penalizing biogas as a vehicle fuel while the Commission proposes a reduced tax on fossil natural gas and fossil LPG used as a vehicle fuel. Tax is also proposed on advanced biofuels, made from raw materials in Annex IX A and B of the Renewables Directive, albeit at a low level. All minimum taxes on biofuels and biofuels should be rejected. We support the proposal to tax according to energy content instead of volume. But the taxation of fossil fuels by energy content should be converted into a carbon dioxide tax. The minimum taxes of the Energy Tax Directive should only be linked to energy content and/or carbon dioxide emissions and should not be used as a means of control for other emissions or environmental impact. These external effects should be regulated in other ways. The design of the regulations for taxation may lead to Sweden being forced to reduce the electricity tax for households and service industries very sharply. This will have very major consequences for Swedish tax policy and energy supply and cause capacity problems during cold winters if electric heating is promoted with lowered taxation.
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

The EU regulation has to change from zero tail-pipe to well-to-wheels and conventional biofuels from crops are much needed also for cars. The EU climate target for the transport sector is far too low, only 13 percent in emission reduction by 2030 compared to the Swedish target of 70 percent reduction. The one-sided focus on electric and hydrogen vehicles and the negative discrimination of biofuels is an important explanation for the low target. . EU control of emissions in the transport sector must be based on climate change, not on the choice of technology or vehicle type. This can best be done through general instruments that penalize fossil fuels, preferably by carbon taxation and tax exemption for renewable fuels. . The valuation of vehicles must be based on emissions throughout the life cycle (well-to-wheels) and not on emissions from the exhaust pipe (tailpipe regulation). This would also be the logical regulation considering that the climate target in RED III is a GHG reduction target. . There is no scientific support for the current policy of valuing vehicles according to emissions from the exhaust pipe. . The term "zero-emission vehicle" must be eliminated from EU legislation. There are no zero-emission vehicles if you look at the vehicles' total environmental impact. For an electric car in Europe, the environmental impact is particularly high from both battery production and electricity supply, where production still largely takes place with fossil fuels. This is confirmed in the recent EU Commission report on the fulfillment of the fuel quality directive (COM 2021/950 final) where it is reported that the GHG values for electric vehicles in six EU Member states varied from 110.3 – 522.9 g CO2/MJ, considerably higher than the fossil fuel comparator of 94.1 g CO2/MJ. The report also shows that practically all of the GHG emission reduction in 2019 was came from the use of biofuels, of which a majority was conventional biofuels made from agricultural crops. . The very best vehicles from a climate point of view are biogas cars that run on biogas made from waste or manure, and efficient diesel vehicles that run on HVO100. These vehicles will in practice be banned from 2035 despite their excellent climate performance. . All other cars that run on biofuels, both conventional and advanced, including e-fuels used in combustion engines, will also be banned without objective reasons or scientific evidence. . EU policy in this area is contrary to the principle of technology neutrality. . From an international perspective, there will for a very long time be a market for cars with internal combustion engines, especially in those parts of the world where there are no or unreliable electricity grids or infrastructure that can supply electric and hydrogen vehicles with fuel. These markets are important for the European car industry and EU exports. A recently published research report from Lund University by professors Öivind Andersson and Pål Börjesson (Öivind Andersson, Pål Börjesson: The greenhouse gas emissions of an electrified vehicle combined with renewable fuels: Life cycle assessment and policy implications, Applied Energy 289, 2021, see file attached) shows that a plug-in hybrid powered by HVO100 has clearly the lowest greenhouse gas emissions, lower than the corresponding electric car, even if one assumes fossil-free electricity production (EU electricity production 2050, but also Swedish power mix today). Even a plug-in hybrid powered by the E85 is better than the electric car. This is even more true if one base the calculation on the current electricity production in the EU. The calculations have been made with LCA analysis and the best available data today for the production of vehicles, batteries and fuels. The research report confirms that the current EU governance with "zero tailpipe" and "zero emission vehicles" does not provide optimal climate benefits.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

Voluntary systems play an important role in verifying compliance, but they also result in administrative burden and costs for the concerned actors. Often, small and medium companies are disproportionally negatively affected. The result can be less mobilisation of biogenic feedstock and less substitution of fossil fuels and thus higher emissions of carbon dioxide. It is therefore essential to limit the regulation and the resulting administrative burden. It is above all essential that implementing regulation is fully aligned with the legal regulation in the directive. This is not the case with this proposal. In several cases, the draft goes far beyond the directive. In effect, this means that the Commission is introducing new criteria that go beyond what has been agreed on in the directive. This is not acceptable. We specifically want to point out these issues: . The draft in Annex IV introduces a new classification of wastes and residues that is not aligned with the definitions in the directive. The preliminary list of “waste and residues” in Annex IV is supposedly based on Annex IX in RED II. It does, however, deviate from the list in Annex IX on major points. Some feedstocks are excluded, others have been added. This is very unfortunate, as Annex IX has been agreed on in negotiations on the directive, with the condition that no feedstock should be removed from the list, whereas new feedstocks could be added. Furthermore, Annex IX was not formulated to define “waste and residues”, but to list feedstocks favoured for production of “advanced biofuels” and qualified for double-counting. Annex IX in RED includes both waste and residues, and primary feedstocks, like cellulosic materials from forestry and agriculture in general (with the exception of saw wood and veneer wood), as well as cultivated algae. The result is that also the new Annex IV list includes cellulosic crops (and mentions only some of these crops but excludes others, particularly Northern European, like willows, poplars and reed canary grass), but excludes cellulosic material in general (wood) from forestry. . It is very disturbing that Annex IV does not mention most of the relevant cellulosic raw materials from forestry, like bark, sawdust, black liquor, raw methanol (from pulp process) and other residues from forest industry. Harvesting residues from felling and thinning are also not mentioned. Also, straw from agriculture and other agricultural residues, like prunings, are excluded. These exclusions will create uncertainty among investors and producers of new advanced biofuels and hamper the development of the bioeconomy. It is in general difficult to make a positive list of all the possible wastes and residues. Our proposal is that this list is removed from the draft, and that the voluntary schemes are based on the definitions in the directive. . The rules for mass balance are unclear as they for some raw material categories require mass balance within 3 months’ time. This is not in line with the practice in the industry, and we strongly urge a change to 12 months for all materials. . In article 26.3, on abandoned farmland, the mentioned socio-economic factors do not include the most important ones: lack of profitability and the effects of EU policy that discourages production. Also, aging population and lack of interest from young people to engage in farming, are more important factors than the mentioned ones. EU policy to discourage from using the farmland for energy crops, is one of many factors hampering development. . As this new regulation includes many new requirements, it is important to give time for implementation. The regulation should therefore not be instantly applied.
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

We regret that the operational guideline has been published with such delay. The national authorities and the actors on the market need time for planning and implementation, as contracts are made for the whole next season for heat plants, CHP:s and industries. In many cases there are complex supply chains involving many sources, both domestic and import. A late and rushed implementation of the sustainability criteria will cause disturbances on the market. The operational guidance goes far beyond the criteria in RED II. It should be aligned with these agreed criteria and follow the wording of the directive. If the Commissions would like to amend the criteria or stretch the definitions, this should be negotiated in a coming revision of the directive. It is not acceptable that the Commissions makes new interpretations in a delegated act like the operational guidance. It is also directly an infringement on the national competence on forest policy. We propose the following changes: Article 2 (j) Delete: larger than or equal to 10 cm in diameter or any other diameter used by the country concerned; These kinds of details should not be specified on EU level. Article 2 (k) Delete: deliver goods, such as wood of various quality grades, and non-wood-forest products and services, including air and water purification, maintenance of wildlife habitat, recreation or cultural capital, over a long period of time, and where applicable, bridging several successive forestry rotations; change to produce wood. The purpose of article 29.6a.v is to ensure long term productivity for forest products (wood), not for other services. Article 3.1b.ii Delete: and that there is no biodiversity degradation in the regenerated forest area, including that primary forests and natural or semi-natural forests are not degraded to or replaced with plantation forests; The bioenergy use is not the driver of the forest operation, and the buyer of the biomass for energy (usually residue) can only guarantee that the forest operation is according to the legislation, including regeneration. Article 3.1b.iii Delete: including areas being defined as wetlands and peatlands; The wording means that all wetlands and peatlands are included, whereas the criteria in the directive only include wetlands and peatlands with conservation status. Much forest in northern Europe grows on drained peatlands that are not protected areas. Article 3.1b.iv Delete: the protection of soils, species and habitats, and regulate the removal of stumps, roots, deadwood, and where appropriate, needles or leaves; and change to the protection of soil and biodiversity, in line with the wording of the directive. Article 3.1b.v Delete: and that it does not hamper the forest’s health and the related ecosystem services; This is a new criteria that was not included in RED II. Article 4.1b.ii Delete: including that primary forests and natural or semi-natural forests are not degraded to or replaced with plantation forests. Bioenergy is not the driver of the forest operation, and has no control over the general management of the forest. Article 4.1b.iv Delete: including no harvesting of stumps and roots and clear-cuts are minimised; The article introduces a number of additional criteria not included in RED II. Stump harvest is allowed in many countries and can be motivated under certain conditions, and is a part of the national competence on forestry. Clear-cut is the predominant harvesting practice in boreal forestry. Other alternatives, like selective cutting, is often not a feasible or competitive alternative. The choice of harvesting method is not decided by the bioenergy actor. Article 6.d) The requirement goes far beyond what an operator can ensure. Not least considering climate change impact over the coming 30 years. The whole point d) should be deleted.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Bioenergy accounts for 38 percent of the final energy use in Sweden. Just like in EU as a whole, bioenergy is the leading renewable energy source and will be a major contributor to climate change mitigation in the coming decades. Without deployment of bioenergy, the climate targets cannot be met. Bioenergy solutions give substantial contribution to climate change mitigation in accordance with Article 10.1 in Regulation EU 2020/852, points a), generating, distributing and using renewable energy in line with the renewable energy directive EU 2018/2001, c) increasing clean and climate-neutral mobility, g) establishing energy infrastructure to enable decarbonisation of energy systems, and h) producing clean and efficient fuels from renewable or carbon-neutral sources. The activities are closely linked to d) switching to sustainably sourced renewable materials, and will enable e) deployment of bio-CCS and bio-CCU in large-scale applications for negative emissions. Based on this, we strongly disagree with the categorisation of bioenergy as a “transitional activity” in the taxonomy. Bioenergy is a renewable energy source on par with all the other renewable energy sources. It is basically solar energy captured by trees and other plants, producing chemically stored energy that can be used both for solid, liquid and gaseous renewable fuels to substitute fossil fuels and play a strategic role in a fully carbon-free and 100 percent renewable energy system. Bioenergy is carbon-neutral and a part of the natural carbon cycle and as such qualifies as a “nature-based solution”. The taxonomy has not captured the immense potential of the land-based sectors, agriculture, forestry and aquaculture, to contribute to climate mitigation. Europe has vast untapped resources of underutilized and abandoned farmland and under-developed forestry. To make use of these resources in an optimal way will reduce emissions from fossil fuels, improve energy security, and create jobs and economic development in rural areas and peripheral regions of EU and in neighbouring countries. The restrictions against agricultural energy crops must be removed. Instead of mobilising these green resources the taxonomy introduces new administrative burdens on farmers and forest owners which will lead to decreased supply of biomass for energy. The sustainability criteria agreed on in RED II are sufficient to guarantee sustainability for biomass and biofuels. By extending reporting on sustainability to heat plants under 20 MW, the taxonomy also increases the administrative burden on hundreds or even thousands of small energy plants around Europe using local biomass as energy source. Svebio fully supports ambitious climate targets and a quick transition of the European energy system. The financial sector will play a central role in this change. In our opinion, EU should use general incentives, primarily carbon pricing, to reach these targets, strengthening ETS and introducing carbon taxes in all member states and all sectors of the economy, combined with fair criteria for sustainability. This will lead to the most cost-effective transition and be in accordance with the fundamental idea of the European Union, to create a free and open common market where different solutions can compete. EU has instead chosen to formulate more and more detailed regulations in a number of directives and acts. The taxonomy, the state aid regulation, the renewable energy and energy efficiency directives, all are full of such detailed regulations where EU favours certain solutions ahead of others, totally contrary to the principle of technology neutrality, which ought to be a guidance for fair legislation. This system, recently described by a professor of environmental economics as “a tsunami of regulations”, opens up for special interests and intense lobbying in Brussels, without resulting in lower greenhouse gas emissions than a system with general incentives and free market.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

Reasons why delayed harvest and storing carbon in forests is not the optimal climate solution. It is essential to safeguard the carbon sequestration in forests and other lands. But one must keep in mind that the forestry and agricultural systems are dynamic and fulfill several functions in parallel. To formulate a target of increasing the EU removals from the current 250 – 300 Mt CO2/year to 500 Mt by 2050 can backfire in the long run. Forests take up CO2 when growing and they store carbon. Compared to fossil carbon deposits this storage is temporary and can easily be threatened by forest fires, pests, storms and other natural disturbances, when most or all of the carbon is released. Old forest and “natural forests” have very limited net CO2 up-take, whereas young forests have high growth rates and high up-take of CO2. As a result, managed forests composed of stands of all age-classes have the highest total sequestration of carbon. With a high harvesting rate, the substitution of fossil materials and fossil energy can be maximized. The development over time in member states with highly developed managed forestry proves that this strategy is best for the climate. High growth rate and high harvesting rate has also led to constant growth of the standing stock in the forests. To focus on carbon storage only can break this win-win-strategy and lead to negative climate effects. Lower harvesting rate will lead to aging forests with gradually lower net CO2 up-take, and eventually to saturation and no net up-take. Meanwhile, substitution will decrease and more fossil energy and materials will be used. A short-term increase in sinks noted in LULUCF will lead to lower sink in the future, and higher emissions in other sectors of the economy. Production of renewable materials and renewable fuels should be the primary activity for agriculture and forestry. These products are renewable, based on solar energy, and they can to a large degree substitute fossil materials and energy, not least by using all wastes and residues in an optimal way. Farmers and forester want to produce, and this also generates income in rural communities and regions in industries and transports. The main activity for farmers and foresters cannot be to store carbon to compensate for emissions from fossil fuels in other sectors. It is, however, in the landowners own interest to safeguard the soil quality, including carbon, and farm methods can be developed to increase carbon content. Finally, a comment to the statement that LULUCF numbers have declined after 2008, and is expected to decline further in coming years. Projections of LULUCF numbers have always been difficult to make. LULUCF in EU27 has varied annually between 251 and 335 Mt CO2 since 2000. The slight decrease during the very last years, mainly after 2016, reflects natural disturbances like forest fires in southern Europe and bark beetle infestations in central and northern Europe. In some countries, aging forest stands can also be an explanation. These changes illustrate how difficult it is to formulate targets for the LULUCF sector. It is important to realize that LULUCF reporting does not include all positive carbon effects of forestry. Carbon storage in wood products is calculated, but not the substitution effects, both for wood products, paper products and biofuels. These effects appear in other sectors of society. The result of the substitution is that fossil carbon remains in geologic long-term storage for millions of years to come.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Answer from Svebio - Swedish Bioenergy Association We strongly support extension of carbon pricing to the sectors outside ETS. But we are not convinced that inclusion in ETS of the heating and transport sectors are the right way to do this. We would instead prefer introducing carbon taxes on sectors outside ETS. It is a simpler and more straightforward incentive than carbon emission trading. With carbon tax, the level of taxation is known to all actors in the market, and easier for the distributors of fossil fuels to handle than a carbon price varying day by day according to the traded price. A carbon tax can be gradually raised, like it is now proposed in Germany, and has been done in France and Ireland. Sweden has had a step-by-step increased carbon tax since 1991 (now the world’s highest), resulting in an almost totally decarbonized heating and service sector. Industries outside ETS also pay a full carbon tax since a couple of years, and substitution of fossil fuels now takes place also in this sector. If the heating sector is included in ETS there is a risk that the carbon price level will decrease in member states where carbon tax rates currently are higher than the price in ETS. The best solution would be to revise the Energy taxation directive and introduce a common mandatory minimum carbon tax level for all EU member states, and leave it up to the member states to have higher rates than this minimum. The carbon tax must be based on energy content and carbon emissions, and there should be no limitations in the state aid regulation for member states to use carbon taxation to reduce emissions. Carbon tax is not a subsidy on alternatives to fossil fuels. Negative emissions from BECCS must be handled with a common framework. This is an urgent issue as a number of projects are planned and under way in the coming years. Stockholm Exergy’s CHP in Stockholm, one of the world’s largest using biomass as fuel, will have a BECCS unit in place before 2025, and capture around 800 000 tons of biogenic CO2. Many other Swedish district heating utilities are also investigating BECCS solutions to offer carbon negative district heating. We fully support including domestic transport modes like intra-EU maritime transports in ETS. For the road transport sector, we prefer to use the Energy taxation directive to introduce a common minimum carbon tax level on all fossil transport fuels.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Sept 2020

Swedish Bioenergy Association (SVEBIO)’s Reply to the Public Consultation on Inception Impact Assessment Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources Svebio, the Swedish Bioenergy Association, is an independent organisation promoting increased bioenergy deployment in an economically and environmentally optimal way. Our members are companies and individuals working in the whole bioenergy supply chain. Bioenergy is Sweden’s largest energy source, supplying 37% of Sweden’s final energy use. The supply of sustainable biomass for energy can double in Sweden according to our analysis in Roadmap Bioenergy – meeting the demand for bioenergy in a fossil free Sweden: https://www.svebio.se/app/uploads/2020/03/Roadmap-Bioenergy-2020.pdf The Renewable Energy Directive, RED II, was adopted just recently, and has not yet been implemented fully in the member states. For the affected companies it creates uncertainty if the directive is revised even before it is implemented. For investments and sound business practice it is important that regulations and incentives are long-term and stable. We therefore strongly advice against opening up for changes in the sustainability criteria. These were adopted after thorough negotiations by the member states. Conclusion: articles 29 – 30 should not be changed. We do however support a revision of the targets in the transport sector. The 14% target 2030 is totally insufficient to reach overall 55% GHG reduction by 2030, and to reach climate neutrality by 2050. This 14% target is not much higher than the 10% target for 2020, when considering double counting, electric vehicles and new fuels. There should be a new target of 30%, or more for the transport sector. To reach an ambitious target for the transport sector, the restrictions for biofuels made from agricultural crops must be removed. Europe has large potentials to produce energy crops on existing farmland and on already abandoned farmland and fallow land. Steadily increased yields, and decreasing population in Europe further free land for growing energy crops. Also, the double counting for certain fuels should be removed as it distorts the market. Conclusion: articles 25 – 28 need to be revised. Also, the targets for the heating/cooling sector, including heat production in industry outside ETS, may have to be revised. The change in this sector should primarily be incentivised by introducing carbon pricing. We prefer introducing carbon taxes in all member states and revising the energy taxation directive, including a minimum carbon tax level. Bioenergy offers reliable renewable energy at a competitive cost. It also creates jobs and incomes in EU when imported fossil fuels are substituted, not least in rural and peripheral areas of Europe. In fact, less than 5 percent of the used biomass energy is imported to the EU making bioenergy to be the largest domestic EU energy source. The import of coal is 44 percent, the fossil gas import is 74 percent of the use and imported fossil oil stands for 93 percent of the use. Bioenergy development should not be restricted, but instead promoted not at least for trade balance reason. The sustainability criteria in RED II guarantee that the use biofuels and biomass fuels are sustainable. These criteria now need to be implemented. We support Option 5 (Possible combinations of option 2,3 and 4): New targets need to be formulated for the transport sector and for heating/cooling. To reach the more ambitious 55% GHG target for 2030, these two sectors must have higher targets than in the current directive, and consequently the overall target for renewable energy needs to be increased. For the transport sector it is important to remove restrictions on energy crop based biofuels. We strongly advice against making a large revision of the directive. We further motivate our argument in the attached document.
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