Q&A: RED II Offers Flexibility to EU Member States

(Argus Media) Angel Alvarez Alberdi is secretary general of the European Waste-to-Advanced Biofuels Association (EWABA). He spoke to Argus about the EU's Renewable Energy Directive (RED) beyond 2020, the role of waste-based biofuels in Europe's future renewable energy mix and legislation on indirect land use change (Iluc). Below is an edited transcript of the interview.

RED II will bring market stability for at least half a decade. The signal to investors is clear: go for waste feedstocks.

Finally, we should not overlook that RED II includes a clause to revise the general 14pc transport target in 2023 — if the commission changes the target it will necessarily need to adapt other major elements of the legislation. This implies it is quite certain RED II will be fine-tuned depending on how markets evolve these next few years.

It will all depend on how the commission drafts the delegated act establishing what is to be considered as high-Iluc risk or low-Iluc risk, due on 1 February 2019.

Existing studies show palm oil will be particularly under fire, but we cannot exclude that a fraction of other feedstocks such as soy, corn, or sugarcane will be equally limited. It is important to stress the criteria for establishing what is to be considered as a low-Iluc fuel will allow for a number of exemptions to the high-Iluc risk rule.

These exemptions should be very carefully designed so as to avoid what some quite rightfully call a 'low-Iluc loophole'.

Multipliers are in principle a good policy mechanism to promote either novel technologies or expensive feedstocks, or both.

They send a clear message to investors and consumers and are undoubtedly an optimal market driver. They have created the waste biodiesel industry and their continuity is tied with the future growth of the industry.

Having said that, multipliers should be reasonable otherwise their legitimacy as policy mechanisms might be widely put into question.

We do not think the same regarding a four-fold multiplier for renewable electricity. Multiplying four times sounds unreasonable, even fictitious — it might have an impact on the public perception of the seriousness of RED II when it comes to promoting electromobility and, quite importantly, it could lead to a negative market squeeze of waste biofuels towards the end of the decade.

By December 2021 the commission will propose a delegated act on a common methodology to calculate the actual contribution of renewable electromobility to be counted four times — all interested parties will need to pay special attention to how this methodology is to be drafted in order to minimise risks.

Could the classification of palm oil mill effluents (Pome) and palm acid oils as waste feedstocks play a large role in achieving future EU targets for renewables in transport?

According to RED II, Pome is an advanced biofuel feedstock. Pome is an unavoidable waste deriving from palm oil production, therefore its use in biofuel production is positive.

We are looking very closely at how Pome is certified and we see so far [it] is a niche market, with small volumes being used in the EU — [sustainability certification scheme] ISCC certified 100,000t of Pome raw material in 2017.

We see increasing Uco volumes from Asia-Pacific over the last few years. RED II establishes Uco-based biodiesel is the commercially available biofuel with the highest typical GHG savings, 88pc compared with fossil fuel.

The German ban (on biofuels from animal fat) was the unfortunate result of a partial assessment by the German authorities which somehow replicated the food versus fuel debate. The truth is that no industry grows cattle for biodiesel production.

Cattle is grown for the food industry and tallow is a by-product with particularly good use as a biodiesel feedstock. We hope the German authorities will eventually reconsider their position on this matter.

There are already highly developed collection networks (for UCO) in Austria, Belgium, the Netherlands and Sweden. [and] regional initiatives of major importance in Italy, Germany, Spain, Portugal, Denmark and Greece. Conservative estimates show there is at least 800,000t of additional collectable household Uco out there. I highlight this is a conservative estimate. READ MORE