This briefing explains the measures necessary for the implementation of Article 7a of the Fuel Quality Directive, and is our response to the EC consultation on the issue.
T&E welcomed the proposal and adoption of article 7a of the Fuel Quality Directive. It provides a technologically-neutral tool to make the fuels consumed in the EU cleaner and less carbon intensive on a lifecycle basis. The appealing aspect of article 7a is the fact that fuel providers can decide to improve the greenhouse gas (GHG) performance of their fuels either by cleaning up the production processes for fossil fuels (i.e. improving efficiency in refineries, reducing flaring and venting, optimising extraction and using cleaner crudes) or by switching to alternative fuels (i.e. biofuels, natural gas, electricity). Maximising the range of options is the best guarantee for future effectiveness: the more mitigation options are left open to fuel suppliers, the more ambitious the reduction targets can be.
T&E is therefore very concerned that the solutions proposed in this public consultation will severely limit the scope of GHG reductions on the fossil side of fuel production, leaving the majority of lifecycle GHG reductions to alternative fuels. This would reduce the principle of technological neutrality and would therefore impair the future effectiveness of the law.
It’s also unfair to demand complete traceability of biofuels feedstock, while not demanding the same for petrol and diesel sold on the EU market, despite the fact that there are substantial differences in the carbon intensity of crude production.
We are convinced that the environmental benefits of accounting for different types of oil extraction and refining outweigh potential disadvantages. Reporting on lifecycle emissions needs to start now in order to create the necessary transparency for future reviews of the law.
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