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  • Expanding and strengthening the carbon accounting of renewables in transport

    Response to the consultation of the European Commission on the accounting methods and conditions for the 10% renewable energy in transport target – and on the need for additional types of biofuels being listed in Annex III of the Renewable Energy Directive

    According to the analysis of the 27 national renewable action plans, the overwhelming majority of the 10% target for renewables in transport will be reached by first generation biofuels (they will indeed account for 9.6% out of 10%). The 2020 target is, therefore, stimulating a major increase in the use of biofuels by 2020, with biofuels remaining the primary approach for delivering renewable energy in the transport sector and for meeting the Renewable Energy Directive’s (RED) 10% target.

    This will have a major impact on carbon emissions, leading to the anticipated conversion of between 4.7 and 7.9 million ha of Indirect Land Use Change (ILUC) by 2020. This means that the EU policy concerning biofuels will have large negative environmental impacts, unless indirect land use change is properly addressed with scientifically robust ILUC factors that discourage the use of high carbon biofuels.

    Moreover, renewable electricity in electric cars, renewable hydrogen and biomethane will play a modest role in meeting the 10% target. Most of it, to the contrary, will be achieved by biofuels with questionable environmental performance. To sum up, the biofuel policy should be fixed, but it is also important to get the correct accounting for other renewables in the transport sector. Furthermore, it is important to expand the sustainability criteria for biofuels to their use in other sectors, such as aviation biofuels that could be used to comply with the ETS and shipping fuels that could help meet the obligations of the upcoming sulphur directive. It would be inconsistent to have strict criteria for road transport and nothing for other sectors. It would be therefore desirable for the Commission to set up binding rules also in this respect, setting sustainability criteria for biofuels displacing bunker fuels as well.