NGOs write to highlight an urgent opportunity to ensure that sustainability standards for bioenergy in the Renewable Energy Directive (RED) and Fuel Quality Directive (FQD) apply as well to the EU Emissions Trading Scheme (ETS).
Before the end of the year the Commission will have to adopt a new Regulation on the monitoring of and reporting of greenhouse gas emissions under the EU ETS. Currently no sustainability criteria apply for bioenergy in the ETS. This leads to the anomalous situation that bioliquids and biofuels deemed unsustainable under the RED and FQD could nevertheless still qualify for emissions reductions under the ETS. Aviation biofuels and bioliquids used in powerplants would be two examples. This inconsistency would compound further if the EU would include the effects of indirect land use change in the sustainability criteria, or adopt binding criteria for biomass.
We believe the Commission should use this opportunity to make sustainability standards for bioenergy present in the RED and FQD apply to the ETS as well.
Whilst such a move would close a very important loophole, a truly sustainable application of bioenergy under the ETS also requires a more fundamental policy change. Annex IV of the ETS directive currently rates all bioenergy as zero carbon, which does not reflect reality. The annex to this letter describes how Annex IV could be changed so that ETS reductions would depend on the climate performance of bioenergy. This would also imply that biomass-only installations would come under the scope of the ETS, which is currently not the case.
We urge you to take our views into account and show leadership on this issue.
