Europaudvalget 2015-16
EUU Alm.del Bilag 605
Offentligt
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A
SUSTAINABLE BIOENERGY POLICY FOR THE PERIOD AFTER
2020
I
NTRODUCTION
EU Member States have agreed on a new policy framework for climate and energy, including
EU-wide targets for the period between 2020 and 2030. The targets include reducing the
Union’s greenhouse gas (GHG) emissions by 40 % relative to emissions in 2005 and ensuring
that at least 27 % of the EU’s energy comes from renewable sources. They should help to
make the EU’s energy system more competitive, secure and sustainable, and help it meet its
long-term (2050) GHG reductions target.
In January 2014, in its Communication on
A policy framework for climate and energy in the
period from 2020 to 2030,
1
the Commission stated that ‘[a]n improved biomass policy will
also be necessary to maximise the resource-efficient use of biomass in order to deliver robust
and verifiable greenhouse gas savings and to allow for fair competition between the various
uses of biomass resources in the construction sector, paper and pulp industries and
biochemical and energy production. This should also encompass the sustainable use of land,
the sustainable management of forests in line with the EU’s forest strategy and address
indirect land-use effects as with biofuels’.
In 2015, in its Energy Union strategy,
2
the Commission announced that it would come
forward with an updated bioenergy sustainability policy, as part of a renewable energy
package for the period after 2020.
Bioenergy is the form of renewable energy used most in the EU and it is expected to continue
to make up a significant part of the overall energy mix in the future. On the other hand,
concerns have been raised about the sustainability impacts and competition for resources
stemming from the increasing reliance on bioenergy production and use.
Currently, the Renewable Energy Directive
3
and the Fuel Quality Directive
4
provide an
EU-level sustainability framework for biofuels
5
and bioliquids.
6
This includes harmonised
1
2
3
4
5
6
COM(2014) 15.
COM/2015/080 final.
Directive 2009/28/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of
the use of energy from renewable sources and amending and subsequently repealing Directives 2001/77/EC
and 2003/30/EC (OJ L 140, 5.6.2009, p. 16).
Directive 98/70/EC of the European Parliament and of the Council of 13 October 1998 relating to the quality
of petrol and diesel fuels and amending Council Directive 93/12/EEC (OJ L 350, 28.12.1998, p. 58).
Used for transport.
Used for electricity, heating and cooling.
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sustainability criteria for biofuels and provisions aimed at limiting indirect land-use change,
7
which were introduced in 2015.
8
In 2010, the Commission issued a Recommendation
9
that included non-binding sustainability
criteria for solid and gaseous biomass used for electricity, heating and cooling (applicable to
installations with a capacity of over 1 MW). Sustainability schemes have also been developed
in a number of Member States.
The Commission is now reviewing the sustainability of all bioenergy sources and final uses
for the period after 2020. Identified sustainability risks under examination include lifecycle
greenhouse gas emissions from bioenergy production and use; impacts on the carbon stock of
forests and other ecosystems; impacts on biodiversity, soil and water, and emissions to the air;
indirect land use change impacts; as well as impacts on the competition for the use of biomass
between different sectors (energy, industrial uses, food). The Commission has carried out a
number of studies to examine these issues more in detail and will also organise a dedicated
stakeholder conference on 13 April 2016.
The development of bioenergy also needs to be seen in the wider context of a number of
priorities for the Energy Union, including the ambition for the Union to become the world
leader in renewable energy, to lead the fight against global warming, to ensure security of
supply and integrated and efficient energy markets, as well as broader EU objectives such as
reinforcing Europe's industrial base, stimulating research and innovation and promoting
competitiveness and job creation, including in rural areas. The Commission also stated in its
2015 Communication on the circular economy
10
that it will ‘promote synergies with the
circular economy when examining the sustainability of bioenergy under the Energy Union’.
Finally, the EU and its Member States have committed themselves to meeting the 2030
Sustainable Development Goals.
7
8
9
10
Biomass production can take place on land that was previously used for other forms of agricultural
production, such as growing food or feed. Since such production is still necessary, it may be (partly)
displaced to land not previously used for crops, e.g. grassland and forests. This process is known as indirect
land use change (ILUC); see
http://ec.europa.eu/energy/en/topics/renewable-energy/biofuels/land-use-change.
See more details on the existing sustainability framework for biofuels and bioliquids in section 5.
COM/2010/0011 final.
Closing the loop – an EU action plan for the circular economy
(COM(2015) 614/2).
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1. G
ENERAL INFORMATION ABOUT RESPONDENTS
1.1. In what capacity are you completing this questionnaire?
academic/research institution
as an individual / private person
civil society organisation
international organisation
other
private enterprise
professional organisation
public authority
public enterprise
1.2. If you are a private or public enterprise, could you please indicate your principal
business sector?
Agriculture
Automotive
Biotechnology
Chemicals
Energy
Food
Forestry
Furniture
Mechanical Engineering
Other
Printing
Pulp and Paper
Woodworking
1.3. If you are a private or public enterprise, could you please indicate the size of
your company?
(Medium-sized enterprise: an enterprise that employs fewer than 250 persons and whose
annual turnover does not exceed EUR 50 million or whose annual balance-sheet total does
not exceed EUR 43 million.
Small enterprise: an enterprise that employs fewer than 50 persons and whose annual
turnover and/or annual balance-sheet total does not exceed EUR 10 million.
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Micro-enterprise: an enterprise that employs fewer than 10 persons and whose annual
turnover and/or annual balance-sheet total does not exceed EUR 2 million.)
large enterprise
medium-sized enterprise
small enterprise
micro-enterprise
I don’t know
1.4. If you are a professional organisation, which sector(s) does your organisation
represent?
Agriculture
Automotive
Biotechnology
Chemicals
Energy
Food
Forestry
Furniture
Mechanical Engineering
Other
Printing
Pulp and Paper
Woodworking
1.5. If you are a professional organisation, where are your member companies
located?
Austria
Belgium
Bulgaria
Croatia
Cyprus
Czech Republic
Denmark
Estonia
Finland
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France
Germany
Greece
Hungary
Ireland
Italy
Latvia
Lithuania
Luxemburg
Malta
Netherlands
Poland
Portugal
Romania
Slovakia
Slovenia
Spain
Sweden
United Kingdom
non-EU country(ies)
1.6. If you are a civil society organisation, please indicate your main area of focus.
Agriculture
Energy
Environment and Climate
Other
Technology & Research
1.7 If you are a public authority, can you define more specifically your area of
competence?
national government
national parliament
regional government
regional parliament
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local authority
government agency
other
1.8. If replying as an individual/private person, please give your name; otherwise
give the name of your organisation
1.9. If your organisation is registered in the Transparency Register, please give your
Register ID number.
(If your organisation/institution responds without being registered, the Commission
will consider its input as that of an individual and will publish it as such.)
1.10.
Please give your country of residence/establishment
Austria
Belgium
Bulgaria
Croatia
Cyprus
Czech Republic
Denmark
Estonia
Finland
France
Germany
Greece
Hungary
Ireland
Italy
Latvia
Lithuania
Luxemburg
Malta
Netherlands
Poland
Portugal
Romania
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Slovakia
Slovenia
Spain
Sweden
United Kingdom
Other non-EU European country
Other non-EU Asian Country
Other non-EU African Country
Other non-EU American Country
1.11.
Please indicate your preference for the publication of your response on the
Commission’s website:
(Please note that regardless the option chosen, your contribution may be subject to a
request for access to documents under Regulation 1049/2001 on public access to
European Parliament, Council and Commission documents. In this case the request
will be assessed against the conditions set out in the Regulation and in accordance
with applicable data protection rules.)
Under the name given:
I consent to publication of all information in my contribution and I declare that none of it
is subject to copyright restrictions that prevent publication.
Anonymously:
I consent to publication of all information in my contribution and I declare that none of it
is subject to copyright restrictions that prevent publication.
Please keep my contribution confidential.
(it will not be published, but will be used internally within the Commission)
2. P
ERCEPTIONS OF BIOENERGY
2.1. Role of bioenergy in the achievement of EU 2030 climate and energy objectives
Please indicate which of the statements below best corresponds to your perception of the role
of bioenergy in the renewable energy mix, in particular in view of the EU’s 2030 climate and
energy objectives:
O
Bioenergy should continue to play a dominant role in the renewable energy mix.
Bioenergy should continue to play an important role in the renewable energy mix,
but the share of other renewable energy sources (such as solar, wind, hydro and
geothermal) should increase significantly.
Bioenergy should not play an important role in the renewable energy mix: other
renewable energy sources should become dominant.
7
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2.2. Perception of different types of bioenergy
Please indicate, for each type of bioenergy described below, which statement best corresponds
to your perception of the need for public (EU, national, regional) policy intervention (tick one
option in each line):
Should be Should be
further
further
promoted
promoted,
but within
limits
Biofuels from food
crops
Biofuels
from
energy
crops
(grass,
short
rotation coppice,
etc.)
Biofuels
from
waste (municipal
solid waste, wood
waste)
Biofuels
from
agricultural
and
forest residues
Biofuels
from
algae
Biogas
from
manure
Biogas from food
crops (e.g. maize)
Biogas from waste,
sewage sludge, etc.
Heat and power
from
forest
biomass
(except
forest residues)
Heat and power
from
forest
residues (tree tops,
branches, etc.)
Heat and power
from agricultural
biomass (energy
crops,
short
rotation coppice)
Heat and power
from
industrial
residues (such as
sawdust or black
liquor)
O
O
O
Should be Should be No opinion
neither
discouraged
promoted
nor
discouraged
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
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Heat and power
from waste
Large-scale
electricity
generation
from
solid biomass
Commercial heat
generation
from
solid biomass
Large-scale
combined heat and
power generation
from solid biomass
Small-scale
combined heat and
power generation
from solid biomass
Heat
generation
from biomass in
domestic
(household)
installations
Bioenergy based
on locally sourced
feedstocks
Bioenergy based
on
feedstocks
sourced in the EU
Bioenergy based
on
feedstocks
imported
from
non-EU countries
Other
(please specify)
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
Please find attached a note with additional views on the perception of bioenergy (in relation to
2.2) [note vedhæftes høringssvaret]:
Additional views on the perception of bioenergy (in relation to 2.2)
The questions in section 2.2 on the perception of bioenergy raise a host of different issues and,
hence, the Danish government would like to comment on the answers given in this section. As a
general remark, promotion of renewables would be most cost effective if done in a technology
neutral way. However, contrary to other renewables like wind and solar, the use of biomass requires
specific consideration in order to achieve the long term target of decarbonisation. The use of some
bioenergy feedstocks results in relatively high GHG emission. Others compete with the production of
food, feed, and materials or give rise to risks concerning biodiversity and environmental issues. As
the market does not take these risks into account, there is a need for public intervention .This section
focuses on different categories of bioenergy and their different inherent risks; it does not express an
overall prioritization between different kinds of renewable technologies. Moreover, the views
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expressed apply to policies at the EU level only, as other considerations and priorities may be more
appropriate at national level in e.g. areas such as taxation.
Biomass for heat and electricity
In the short and medium term it will most likely be possible to use bioenergy from agricultural
residues as well as thinnings and residues from forests with low greenhouse gas emissions in a
sustainable way without severe sustainability risks.
In the longer run, however, several studies have concluded that sustainable biomass can be foreseen
to become a scarce resource
11
after 2030, if global biomass mobilization and use increase
significantly. This could on the one hand provide incentives for new investments in increased
biomass production both within and outside forests. It could also, however, risk fueling use and
management practices, in particular in already established forests, which would go beyond the limits
for sustainable use and potentially be associated with high GHG emissions. This should also be seen
in the context of an increased need for using biomass for other purposes such as food, feed and
fibre. Considerations of energy security make it potentially relevant before 2030 to evaluate the
market framework conditions for the future use of biomass resources for purposes for which
bioenergy has a specific advantage compared to other renewable energy technologies such as hydro,
solar, and wind.
Feedstock type:
Denmark finds it important to promote the use of sustainable biomass feedstock in order to achieve
significant CO2 reductions and avoid negative impacts. It is widely accepted that the type of
feedstock is important for the sustainability of bioenergy. Waste, manure, sewages sludge, and
agricultural residues are examples of feedstocks that can be used without major risk of violating
sustainability requirements. Energy crops on agricultural land should be promoted with greater care
in order to achieve high GHG-reductions and avoid ILUC as well as negative impacts on environment
and biodiversity.
Origin of biomass:
The sustainability risks associated with biomass from different countries differ. In some areas non-
compliance is the major issue, where as in other areas insufficient environmental protection is the
main concern. This includes possible high levels of associated GHG emissions as well as concerns for
biodiversity conservation. Biomass trading is increasing and the supply chains are becoming more
global and complex. This means that it is necessary to establish common sustainability criteria and
sufficient chain of custody standards in order to make sure that the measures for tracing the biomass
flows are effective.
Bioenergy and other renewables
Electricity based on wind and solar play an increasing role in the decarbonisation of the energy
system as they do e.g. not entail the risks that follow from the use of potentially unsustainable
bioenergy. In general, the EUs long term targets can be reached through a broad range of different
renewable technologies and sources, and long term sustainable solutions should therefore be
promoted in relevant regulation.
11
”Analyse af bioenergi i Danmark”, Energistyrelsen, 2014. ”Carbon impacts of biomass consumed in the EU:
quantitative assessment”. DG ENER/C1/427, December 2015.
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Bioenergy for transport
Even with strong regulatory measures electricity based on renewables cannot realistically supply all
energy demand for transport towards 2030, and especially in sectors such as long haul vehicles,
aviation and marine transport biofuels will probably be dominant. When it comes to biofuels those
based on waste or residues should be promoted rather than those based on food crops, because in
general waste or residue based biofuels have less negative impacts in terms of ILUC-consequences,
the risk of increasing food prices, loss of biodiversity and so forth.
Over time focus on resource management and promotion of cascading uses of biomass is likely to
increase. This heralds a future with stronger competition for the resource bases of even waste and
residue based biofuels.
The incentives for using waste or residue based biofuels should create certainty for investors. A
subtarget for 2020 of 0.5 pct. focusing on so called advanced biofuels was already introduced with
the change of the Renewable Energy Directive in 2015 (the ILUC-directive) , and a target post 2020
should be analyzed further.
If biofuels based on food crops are needed to complement electricity and waste and residue based
biofuels in order to secure sufficient emission reductions to reach the 2030 target, it must be
ensured that they deliver real emission reductions. This means that inter alia ILUC-effects have to be
taken into account.
3. B
ENEFITS AND OPPORTUNITIES FROM BIOENERGY
3.1. Benefits and opportunities from bioenergy
Bioenergy (biofuel for transport, biomass and biogas for heat and power) is currently
promoted as it is considered to be contributing to the EU’s renewable energy and climate
objectives, and also having other potential benefits to the EU economy and society.
Please rate the contribution of bioenergy, as you see it, to the benefits listed below (one
answer per line):
of critical important
importance
Europe’s
energy
security: safe, secure
and affordable energy
for European citizens
Grid
balancing
including
through
storage of biomass (in
an electricity system
with a high proportion
of electricity from
intermittent
O
neutral
negative
No opinion
O
O
O
O
O
O
O
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renewables)
Reduction of GHG
emissions
Environmental benefits
(including biodiversity)
Resource
efficiency
and waste management
Boosting research and
innovation in bio-based
industries
Competitiveness
of
European industry
Growth
and
jobs,
including in rural areas
Sustainable
development
in
developing countries
Other
(please specify)
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
3.2. Any additional views on the benefits and opportunities from bioenergy? Please
explain.
Please find attached a note with additional views on the benefits and opportunities from
bioenergy (in relation to 3.2) [note vedhæftes høringssvaret]:
Additional views on the benefits and opportunities from bioenergy (in relation to 3.2)
Bioenergy has several benefits compared to other renewable energy sources. Bioenergy can be
stored and used in a flexible way in a future energy and transport system with a high share of
intermittent electricity production from wind and solar PV. Bioenergy can replace fossil fuels and
thereby help to diversify the national energy mix, thus alleviating the import fuel dependency.
The production of biogas using anaerobic digesters has the potential to reduce GHG emissions in
agriculture by improving the management of manure in intensive animal production systems.
In 2012, the Commission published a bioeconomy strategy for Europe. This strategy points to the
benefits from increased mobilisation of biomass resources, such as creation of jobs and growth in
rural areas and, further, that the investments in bioenergy and biobased industries could contribute
to innovation and technology development. A strong and diversified market for the use of biomass
resources will also stimulate further research and development which can help pave the way towards
a more resource efficient use of biomass in biorefineries.
An increased use of bioenergy could provide incentives for new investments in forestry, e.g. the
introduction of new silviculture methods, where plantings with tree species aimed at long term
production of high stem forests are combined with plantings of nurse trees in the same location, but
aimed at short term production of energy wood. However, without specific protective policies and
actions in place it could also risk leading to intensified harvesting and generally shorter rotation
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periods with less dead wood left in the forest and likely negative impacts on biodiversity. It is also
important to note that production of biomass in some cases, if carried out in the right manner, can
provide environmental benefits, i.e. reduced nitrate leaching in cultivated areas and increased
sequestration of carbon into plants, litter and soil. The harvesting of biomass from certain managed
ecosystems such as pastures and grassland can also help to increase the biodiversity such as plants,
insects etc.
R&D
The largest single cost for producing bioenergy is the feedstock. Therefore, there is a large potential
for improving the economy of bioenergy if research is focused on developing the biomass feedstock.
The biomass supply will be both from conventional agriculture and forestry, organic waste streams as
well as dedicated bioenergy crops.
Optimization of the biomass production will require research in factors and processes controlling the
productivity and resource-use-efficiency of novel biomass production systems. Interactions between
genotype, environment and management factors can be exploited to sustainably intensify the
biomass yield per unit land area. In addition, there is a potential in further development of existing
engineered biofuel crop plants. Further research on the impact of increasing the use of bioenergy
crops on air quality and the climate is necessary.
4. R
ISKS FROM BIOENERGY PRODUCTION AND USE
4.1. Identification of risks
A number of risks have been identified (e.g. by certain scientists, stakeholders and studies) in
relation to bioenergy production and use. These may concern specific biomass resources
(agriculture, forest, waste), their origin (sourced in the EU or imported) or their end‑uses
(heat, electricity, transport).
Please rate the relevance of each of these risks as you see it (one answer per line):
critical
Change in carbon stock due
to deforestation and other
direct land-use change in
the EU
Change in carbon stock due
to deforestation and other
direct land-use change in
non-EU countries
Indirect land-use change
impacts
GHG emissions from the
supply
chain
(e.g. cultivation, processing
and transport)
GHG
emissions
from
O
significant
O
not very non-
significant existent
O
No
opinion
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
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combustion of biomass
(‘biogenic emissions’)
Impacts on air quality
Impacts on water and soil
Impacts on biodiversity
Varying
degrees
of
efficiency
of
biomass
conversion to energy
Competition
between
different uses of biomass
(energy, food, industrial
uses) due to limited
availability of land and
feedstocks and/or subsidies
for specific uses
Internal market impact of
divergent
national
sustainability schemes
Other
(please specify)
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
4.2. Any additional views on the risks from bioenergy production and use? Please
explain
Please find attached a note with additional views on the risks from bioenergy production and use
[note vedhæftes høringssvaret]:
Additional views on the risks from bioenergy production and use
A number of studies have pointed to risks related to the sustainability of biomass used for bioenergy
as well as other purposes. It is of increasing importance that these risks are mitigated in an efficient
way, which makes sure that the benefits of bioenergy outweighs the negative effects on the
environment as well as adverse impacts on the market for biomass feedstock used for other
products.
The European Commission is currently carrying out a number of studies related to increased use of
bioenergy and the associated risks. It is important that these studies are used to inform the policy
process and that the conclusions are taken into account when designing any measures that should
mitigate and remove the risks from bioenergy production and use.
A recent study on land use change commissioned by the Commission confirms the results found by
earlier studies (notably the IFPRI study from 2011), namely that there are considerable land use
change emissions from biofuels based on food crops, and especially from biodiesel based on
vegetable oils. Another recent study published by the Commission is a quantitative analysis of
biogenic carbon emissions related to the use of bioenergy (Matthews, R. et al. 2015). This analysis
shows that various types of bioenergy have impact on the concentration of GHG in the atmosphere
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and that the climate impacts are sensitive to a number of parameters such as the used feedstock,
forest/plant productivity as well as alternative uses of the land and the biomass resources.
The Danish government has the following comments on the overall categories related to the
sustainability risks associated to the increased use of bioenergy:
GHG emissions
The climate change effects from bioenergy use have been analysed in several Life Cycle Approach
(LCA) studies. When using a consequential LCA approach to analyze the global GHG effects of
bioenergy use the results show that the use of biomass for energy purposes will impact the
concentration of GHG in the atmosphere, especially if the entire supply chain is considered and the
indirect effect on land use change and material substitution are taken into account.
Different bioenergy scenarios show a rather large difference in the emissions associated with the
production and use of bioenergy. The results are sensitive to the assumptions on the feedstock and
the volume of biomass used energy. In some scenarios bioenergy production can provide substantial
GHG emissions savings compared to fossil fuels. In other scenarios the use of bioenergy is not
contributing to the GHG emissions savings.
In general, bioenergy produced from biomass residues and waste will have a low impact on the
environment, if there are no alternative uses of the biomass. Biomass produced on marginal farm
land with a short rotation length can also have a low carbon impact if the ILUC-effect is low.
On the other hand, changes in the carbon stocks due to deforestation, forest degradation and other
direct land-use change can lead to high GHG emissions in the short and medium term. This could for
example be a more systematic conversion of mature forests with high levels of standing volume to
faster growing plantations with a lower standing volume and perhaps not in full accordance with the
principles of sustainable forest management. This is probably more likely to happen in countries with
weak regulation on forest management. In a longer perspective such conversion might lead to
reduced net emissions due to the increased annual uptake in forests, but the time horizon for
reaching the turning point might be very long.
Environmental impacts
Public acceptance of the use of bioenergy is becoming more important as the use of bioenergy
increases. Environmental aspects such as biodiversity and environmental effects are significant in this
regard. An intensified use of marginal farmland and production of wood in previously more
extensively used forests tends to adversely impact the environment (air, water and soil) as well as
biodiversity. Depending of the origin, even greater risks can be associated with imported biomass
from countries outside EU, especially developing countries with weak forest governance and
insufficient environmental and ecosystem protection.
Resource efficiency
Biomass should be regulated, with a view to taking into account the related externalities.
Air impacts
Depending on the fuel that biomass is replacing, there is risk of increased emissions of NOx, SOx,
particles and other polluting substances, especially when using biomass in combustion plants. In
order to not impede the targets for air quality when achieving the climate and energy targets, it is
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necessary to keep a close eye on the air emissions from biomass, and possibly include special or extra
exhaust cleaning in the biomass activities.
5. E
FFECTIVENESS
BIOLIQUIDS
OF EXISTING
EU
SUSTAINABILITY SCHEME FOR BIOFUELS AND
In 2009, the EU established a set of sustainability criteria for biofuels (used in transport) and
bioliquids (used for electricity and heating). Only biofuels and bioliquids that comply with the
criteria can receive government support or count towards national renewable energy targets.
The main criteria are as follows:
Biofuels produced in new installations must achieve GHG savings of at least 60 % in
comparison with fossil fuels. In the case of installations that were in operation before 5
October 2015, biofuels must achieve a GHG emissions saving of at least 35 % until 31
December 2017 and at least 50 % from 1 January 2018. Lifecycle emissions taken into
account when calculating GHG savings from biofuels include emissions from
cultivation, processing, transport and direct land‑use change;
Biofuels cannot be grown in areas converted from land with previously (before 2008)
high carbon stock, such as wetlands or forests;
Biofuels cannot be produced from raw materials obtained from land with high
biodiversity, such as primary forests or highly biodiverse grasslands.
In 2015, new rules
12
came into force that amend the EU legislation on biofuel sustainability
(i.e. the Renewable Energy Directive and the Fuel Quality Directive) with a view to reducing
the risk of indirect land‑use change, preparing the transition to advanced biofuels and
supporting renewable electricity in transport. The amendments:
limit to 7 % the proportion of biofuels from food crops that can be counted towards
the 2020 renewable energy targets;
set an indicative 0.5 % target for advanced biofuels as a reference for national targets
to be set by EU countries in 2017;
maintain the double-counting of advanced biofuels towards the 2020 target of 10 %
renewable energy in transport and lay down a harmonised EU list of eligible
feedstocks; and
Introduce stronger incentives for the use of renewable electricity in transport (by
counting it more towards the 2020 target of 10 % renewable energy use in transport).
5.1. Effectiveness in addressing sustainability risks of biofuels and bioliquids
In your view, how effective has the existing EU sustainability scheme for biofuels and
bioliquids been in addressing the risks listed below? (one answer per line)
Effective
Partly
effective
Neutral
Counter-
productive
No
opinion
12
Directive (EU) 2015/1513 of the European Parliament and of the Council of 9 September 2015 amending
Directive 98/70/EC relating to the quality of petrol and diesel fuels and amending Directive 2009/28/EC on
the promotion of the use of energy from renewable sources (OJ L 239, 15.9.2015, p. 1).
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GHG
emissions
from
cultivation, processing and
transport
GHG emissions from direct
land-use change
Indirect land-use change
Impacts on biodiversity
Impact on soil, air and water
Any additional comments?
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
The existing scheme with threshold values for direct emissions and verification procedures have gone
some way to prevent the low performing biofuels from entering the market. However, the existing
sustainability scheme does not take into account the ILUC-effect. Therefore, the existing scheme has
promoted the establishment of a large industry, a considerable part of which delivers small or in
some cases practically no emission reductions if the ILUC-effect were taken into account. This holds
especially true for the biodiesel sector.
(2500 characters maximum)
5.2. Effectiveness in promoting advanced biofuels
In your view, how effective has the sustainability framework for biofuels, including its
provisions on indirect land‑use change, been in driving the development of ‘advanced’
biofuels, in particular biofuels produced from ligno-cellulosic material (e.g. grass or straw) or
from waste material (e.g. waste vegetable oils)?
O
O
O
O
very effective
effective
neutral
counter-productive
no opinion
What additional measures could be taken to further improve the effectiveness in promoting
advanced biofuels?
Double counting has promoted some forms of waste based biofuels, notably biodiesel based on
animal fat or used cooking oil (UCO). However, the existing regulation has not been able to underpin
the development of biofuels based on other feedstocks, such as ligno-cellulose or cellulose from
agricultural or forest residues. Additional measures are needed to promote the latter, in order to
broaden the feedstock basis of biofuels, and hence these should be analyzed further.
(2500 characters maximum)
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5.3. Effectiveness in minimising the administrative burden on operators
In your view, how effective has the EU biofuel sustainability policy been in reducing the
administrative burden on operators placing biofuels on the internal market by harmonising
sustainability requirements in the Member States (as compared with a situation where these
matter would be regulated by national schemes for biofuel sustainability)?
O
O
O
very effective
effective
not effective
no opinion
What are the lessons to be learned from implementation of the EU sustainability criteria for
biofuels? What additional measures could be taken to reduce the administrative burden
further?
The introduction of harmonized sustainability criteria for transport biofuels and voluntary
certification schemes approved by the Commission have reduced administrative burdens for the
companies that have to prove sustainability, and have made cross border trade easier.
5.4. Deployment of innovative technologies
In your view, what is needed to facilitate faster development and deployment of innovative
technologies in the area of bioenergy? What are the lessons to be learned from existing
support mechanisms for innovative low-carbon technologies relating to bioenergy?
Long term Research and Development (R&D) programs are needed if we are to exploit the full
potential of bioenergy in the EU energy system. The use of bioenergy involves numerous pathways
and conversion routes which needs further development if they are to play a role in the future. R&D
efforts are needed in different parts of the value chain. There must be a link between R&D and the
framework conditions for using bioenergy in the energy system in order to make it possible for
innovative technologies to leave the laboratory and come into operation. Sustainability criteria
should be a part of the framework condition in order to avoid the use of unsustainable types of
bioenergy and provide the most sustainable and efficient types a competitive advantage.
6. E
FFECTIVENESS
OF EXISTING
EU
POLICIES IN AD DRESSING SOLID AND GASEOUS
BIOMASS SUSTAINABILITY ISSUES
6.1. In addition to the non-binding criteria proposed by the Commission in 2010, a
number of other EU policies can contribute to the sustainability of solid and
gaseous bioenergy in the EU. These include measures in the areas of energy,
climate, environment and agriculture.
In your view, how effective are current EU policies in addressing the following risks of
negative environmental impacts associated with solid and gaseous biomass used for heat and
power? (one answer per line)
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Effective
Change in carbon stock due
to deforestation, forest
degradation and other direct
land-use change in the EU
Change in carbon stock due
to deforestation, forest
degradation and other direct
land-use change in non-EU
countries
Indirect land-use change
impacts
GHG
emissions
from
supply
chain,
e.g. cultivation, processing
and transport
GHG
emissions
from
combustion of biomass
(‘biogenic emissions’)
Air quality
Water and soil quality
Biodiversity impacts
Varying
degrees
of
efficiency
of
biomass
conversion to energy
Competition
between
different uses of biomass
(energy, food, industrial
uses) due to limited
availability of land and
feedstocks
Other
(please specify)
O
Partly
effective
O
Neutral
Counter-
productive
O
No
opinion
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
6.2. Any additional views on the effectiveness of existing EU policies on solid and
gaseous biomass? Please explain
There are a number of existing EU policies in place which have an impact on the use of especially
solid biomass for energy. Some of these policies are:
The EU Emissions Trading Scheme
The Renewable Energy Directive
The European Union Timber Regulation
The Common Agricultural Policy and Rural Development Program
The EU LULUCF decision
The EU biodiversity strategy
The EU forest strategy and the Standing Forest Committee
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The policies listed are targeting different areas related to biomass sustainability and they are related
to different parts of the biomass supply chain (from production and harvesting to distribution and
end use).
It is important to note that there are no mandatory EU policies in place directly targeting all relevant
sustainability risks associated with the use of solid and gaseous biomass for heating, cooling and
electricity. The answers given in section 5.1 on the effectiveness of current EU policies are reflecting
this fact.
The renewable energy directive is currently encouraging the use of bioenergy, but it does not have
the sufficient measures to assure mitigation of the risks related to the production and use of solid
biomass for bioenergy. Therefore the Danish government supports a new EU bioenergy sustainability
policy for the period after 2020.
Currently, the lack of common EU regulation on biomass sustainability has an adverse impact on the
international trade of solid biomass due to the different national sustainability schemes. The
differences in the national regulation have the risk of leading to arbitrage and limiting the
environmental and cost effectiveness of national regulation. Further, the biomass producers are
faced with different regulatory requirements in different EU Member States and this is likely to result
in increased transaction costs.
7. P
OLICY OBJECTIVES FOR A POST
-2020
BIOENERGY SUSTAINABILITY POLICY
7.1. In your view, what should be the key objectives of an improved EU bioenergy
sustainability policy post-2020? Please rank the following objectives in order of
importance: most important first; least important 9th/10th (you can rank fewer
than 9/10 objectives):
1st
Contribute to climate
change objectives
Avoid
environmental
impacts (biodiversity, air
and water quality)
Mitigate the impacts of
indirect land-use change
Promote efficient use of
the biomass resource,
including
efficient
energy conversion
Promote free trade and
competition in the EU
among all end-users of
the biomass resource
Ensure long-term legal
certainty for operators.
Minimise administrative
burden for operators
O
2nd
O
O
O
3rd
O
4th
O
O
5
th
O
O
6
th
O
O
7th
O
O
8
th
O
O
9th
O
O
10th
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
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Promote energy security
Promote EU industrial
competitiveness, growth
and jobs
Other
(please specify)
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
7.2. Any other views? Please specify
The answers under 6.1 show a rank of the five most important objectives for a new EU sustainable
bioenergy policy according to view of the Danish government. It is important to emphasise that there
is not necessarily a trade-off between the different objectives, and that the objectives which have
not been ranked are also important and should also be considered when designing a new EU policy
for sustainable bioenergy.
8. EU
ACTION ON SUSTAINABILITY OF BIOENERGY
8.1. In your view, is there a need for additional EU policy on bioenergy
sustainability?
O
No: the current policy framework (including the sustainability scheme for biofuels
and bioliquids, and other EU and national policies covering solid and gaseous
biomass) is sufficient.
Yes: additional policy is needed for solid and gaseous biomass, but for biofuels and
bioliquids the existing scheme is sufficient.
Yes: additional policy is needed on biofuels and bioliquids, but for solid and gaseous
biomass existing EU and national policies are sufficient.
Yes: a new policy is needed covering all types of bioenergy.
O
O
8.2. In your view, and given your answers to the previous questions, what should the
EU policy framework on the sustainability of bioenergy include? Please be
specific
Denmark will strongly encourage the European Commission to develop a proposal for mandatory
sustainability criteria which covers all uses of bioenergy.
A common set of criteria can ensure the functioning of the internal market and minimize
administrative burdens for producers and operators. The criteria should build on the experiences
with existing national initiatives in Member States such as DK, UK, NL and BE. Further, the commonly
used and widely recognized sustainable forest management criteria and indicators developed under
Forest Europe should form the basis for a new EU sustainable bioenergy policy.
In Denmark, the energy sector has made an industry agreement in order to ensure sustainable wood
pellets and wood used in energy plants above 20 MW. The sustainability criteria follows the
recommendations from the European Commission on national sustainability criteria for solid and
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gaseous biomass and, further, it also contain specific requirements concerning legality, protection of
forest ecosystems, productivity and biodiversity (inspired by Forest Europe, the UK regulation and
the Danish criteria for public procurement of timber). An English version of the industry agreement is
attached.
Regarding transport fuels, the framework should take into account the ILUC-effect caused by
especially food based biofuels but potentially also energy crop based biofuels. The framework could
promote biofuels with low risk of ILUC-effects e.g. biofuels based on waste and residues, for instance
it should be considered setting a subtarget for such biofuels. It is important to analyze the costs of
any regulation.
9. A
DDITIONAL CONTRIBUTION
Do you have other specific views that could not be expressed in the context of your replies to
the above questions?
An English version of the voluntary industry agreement on sustainable biomass is attached.
Finally, you may upload any relevant documents, e.g. position papers, that you would like the
European Commission to be aware of.
Thank you for participation to the consultation!
22