Fit for 55 Package: Further Legislative Fine-Tuning on Draft Proposals Required to Avoid Climate and Economic Damage

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July 19, 2021

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(EWABA) The EWABA association, representing the EU waste-based and advanced biodiesel industry, welcomes the Commission’s intention to make Europe the first climate neutral continent, in words of Commission President Ursula von der Leyen. We regret however that the Commission’s approach fails to offer a bolder promotion of renewable and low carbon liquid fuels as a longterm solution to decarbonize the EU transport sector as a whole. EWABA Secretary General Angel Alberdi stated that “it is clear from the onset that the Commission’s proposals will require further work at the European Parliament and Council of the EU to deliver the best possible regulatory outcome in terms of greenhouse gas (GHG) savings and sustained growth of the EU economy, in particular regarding the ReFuelEU aviation proposal”.

EWABA takes note of the Commission’s proposed revision of the Renewable Energy Directive – REDII. The Commission has proposed a new GHG savings target system to further decarbonize the transport sector. Waste-based and advanced biodiesel reach up to +90% GHG savings compared to fossil diesel and therefore these types of biodiesel are expected to remain the most effective decarbonisation tool for road transport.

We believe that the ReFuelEU proposal on the promotion of sustainable aviation fuels (SAF) breaks the Commission’s technology neutrality principle and severely destabilizes the level playing field between the promotion of renewable and low carbon fuels in the road, maritime and aviation transport sectors while increasing GHG emissions at the expense of the EU’s climate mitigation efforts. The ReFuelEU proposal should not go beyond the system established in the REDII for the promotion of SAF derived from waste lipids. A separate SAF blending mandate including waste lipids from parts A and B of Annex IX will lead to the immediate collapse of the EU’s waste & advanced biodiesel industry due to lack of feedstock to process, forcing the closure of 50+ plants. Novel and scalable technologies such as electrofuels, cellulosic-to-aviation or SAF via syngas conversion should be instead promoted, as currently happening in Germany and the UK.

By setting GHG intensity targets for the maritime sector, the FuelEU maritime proposal can ramp up the use and production of sustainable alternative fuels in the coming years. It is expected that the contribution of waste-biodiesel, an energy dense fuel solution that is already being deployed without engine modifications, will be severely limited due to the ReFuelEU initiative, which will leave no volumes available to maritime suppliers.

On a very positive note, EWABA welcomes the revised Fuel Quality Directive (FQD) including an increase of the biodiesel blend from 7% to 10%, making B10 the standard blend across the EU, from the current B7. Waste-based biodiesel is today’s main tool for reducing emissions and displacing fossil fuel in road transport, since it has the highest GHG savings under Annex V of the REDII. Larger penetration of waste biofuels should be promoted across the road and maritime
sectors, but the volumes needed to achieve B10 will be difficult to obtain as a significant amount of sustainable waste-based feedstocks will be diverted to aviation.

EWABA looks forward to continuing working with the European Parliament and Council to ensure that today’s proposals are improved by giving a more appropriate level of promotion of wastebased and advanced biodiesel, thus ensuring technology neutrality, increasing GHG savings and the sustainable growth of the EU industry.

About EWABA
EWABA is a Brussels-based association representing the interests of the European waste-based and advanced biofuels industry before EU institutions, national governments, industry, civil society and the media. We promote the inclusion of waste-based and advanced biofuels in the EU fuel mix as a sustainable means of reducing greenhouse gas emissions in EU transport. Our +35 members active in most EU Member States collect and use waste and advanced feedstocks
listed in parts A and B of Annex IX of the Renewable Energy Directive (REDII) to produce sustainable biodiesel with the highest GHG savings (up to +90%) when compared with fossil fuels, thus enabling “near-term decarbonization” of the EU road and maritime transport sectors. READ MORE

NGVA Europe comments on EU ‘Fit for 55’ climate package (NGV Journal/NGVA Europe)

Article/interview: ‘”I like to swim against the stream”- why VW’s former gas drive guru is now drumming for biomethane instead of e-cars’ (NGVA Europe/ Business Insider)

ePURE: Fit for 55 needs a biofuels boost (Ethanol Producer Magazine/ePURE)

EU’s ‘Fit for 55’ package threatens biomass progress, says Bioenergy Europe (Bioenergy Insight)

EWABA argues further ‘fine tuning’ of EU’s climate change package needed (Biofuels International)

EU Climate Policy: New Costs for Polluting Heat and Transportation (Our Daily Planet)

Excerpt from NGV Journal/NGVA Europe: Setting an ambitious 2035 target of a 100% reduction in CO2 without recognizing the potential of renewable fuels in cutting the GHG emissions of road transport would mean a de facto ban and lead to transfer of technology out of Europe. The reduction of CO2 in transport is much more about the decarbonization of the energy employed, rather than the underlying drive-train technology: an internal combustion engine (ICE), fueled with renewable sustainable fuels such as biomethane, has a carbon footprint comparable to that of an electric vehicle or even less than that.

While it is essential to drastically lower transport emissions, the EC has failed to allow the EU to enable climate neutrality for transport in a swift and socio-economically efficient manner. That is because this approach prevents the EU from reaping the great benefits yielded from additional CO2 savings stemming from renewable sustainable fuels such as biomethane, while failing to ensure that the transition towards carbon neutral mobility does not leave anyone behind. In doing so, the EU is at the same time contradicting its own principle of technology neutrality.

“Together with many hundreds of associations, companies and scientists, NGVA Europe has already laid out several joint letters and calls, addressing these common concerns.[1] [2] [3] [4] Neglecting the chance for immediate, additional CO2 savings through renewable sustainable fuels and the major role that gmobility can play in this regard will severely curtail the dynamic deployment of renewable fuels precisely where the market demands them,” added Andersen. “NGVA Europe believes that a mechanism, such as—for example—a voluntary crediting system for sustainable renewable fuels [5], can be the necessary solution and is looking forward to discussing this proposal with EU policymakers, the industry, and its members in addition to regional and social partners.”

Gas as a transport fuel offers important benefits to consumers, the environment and the economy. It is available as (bio)CNG for passenger cars and buses in addition to (bio)LNG for heavy-duty transport and the maritime sector, and provides a quick and cost-effective method to meet the key EU objectives, including the decarbonization of road transport and improvement of air quality in cities. Biomethane or synthetic gas from renewable sources can reduce CO2 emissions significantly, or even yield negative GHG emissions.[6]

[1] https://www.ngva.eu/medias/joint-open-letter-on-the-future-of-vehicle-co2-standards/
[2] https://www.ngva.eu/medias/joint-letter-on-renewable-fuels-strategy-and-contribution-to-vehicle-co2/
[3] https://www.ngva.eu/medias/call-to-include-a-voluntary-crediting-system-for-sustainable-renewable-fuels-into-the-vehicle-co2-regulations/
[4] https://www.ngva.eu/wp-content/uploads/2021/07/Press_release_on_the_open_letter_to_the_EU_Commission_final.pdf
[5] https://www.ngva.eu/medias/call-to-include-a-voluntary-crediting-system-for-sustainable-renewable-fuels-into-the-vehicle-co2-regulations/
[6] https://www.ngva.eu/medias/new-study-published-co2-emission-abatement-costs-of-gas-fuelled-mobility-and-other-road-transport-options/