Consultation response

T&E’s response to roadmap consultation on the inception impact assessment for the Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources

September 25, 2020

In the context of the EU Green Deal, T&E welcomes the Commission’s intention to revise the Renewable Energy Directive and, in particular, its transport aspects. While we acknowledge that the adopted REDII is a step in the right direction concerning renewable transport fuels, we consider there are risky loopholes and lack of ambition in several aspects, for instance, the fact that food and feed based biofuels can still be used and counted towards the targets.

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For the upcoming RED revision, we propose the Commission focuses on the following elements:

– Ensure that a target for advanced renewable fuels in transport is based on a robust impact assessment of the availability of sustainable fuels.

– Phase-out food and feed based biofuels as soon as possible. Phase-out high ILUC risk biofuels (including soy) by 2021 and eliminate loopholes such as the low ILUC risk category.

– Ensure more robust sustainability criteria for advanced biofuels that takes into account competing uses and other key principles such as cascading and sustainable residues removal rates. Revise Annex IX to remove problematic feedstocks.

– Ensure a harmonised GHG savings requirement for all fuels, of at least 70%.

– Ensure proper chain of custody for advanced biofuel feedstocks – and other alternative fuels -that ensures traceability.

– Include a credit mechanism that offers a level-playing field for all advanced fuels in all EU member states, to enable fuel suppliers to use renewable electricity to meet their obligations.

– Adopt stringent sustainability safeguards for Renewable Fuels of Non-Biological Origin, making the RED the sustainability framework for their use in all transport modes, including aviation and shipping.

– Decarbonisation targets for the aviation and shipping industries – where direct use of renewable electricity is not feasible – must be closely coordinated and harmonised with the RED targets to avoid driving unsustainable volumes of alternative fuels. The RED targets should remain focused on road and rail transport.