Bundesverband der Deutschen Bioethanolwirtschaft e.V./German Bioethanol Industry Association (BDBe)
Deutscher Bauernverband e.V./German Farmers' Association (DBV)
Union zur Förderung von Oel- und Proteinpflanzen e.V./Union for the Promotion of Oil and Protein Plants (UFOP)
Verband der Deutschen Biokraftstoffindustrie e.V./Association of the German Biofuels Industry (VDB)
Verband der ölsaatenverarbeitenden Industrie in Deutschland e.V./Association of the Oilseed Crushing and Oil Refining Industry in Germany (OVID)
The Guiding Principle: Promoting Sustainable Biofuels from Agricultural Sources
Biofuels account for c. 5% of energy consumption in the German transport sector nowadays (2015: 31.6 billion KWh). This results in annual savings of approximately 6.7 million (metric) tons of CO2 emissions. Biofuels are now one of the most important sources of renewable energy in the transport sector; the contribution made by renewable electricity corresponds to roughly one-ninth of total biofuel consumption (3.7 billion KWh p.a.). Biofuel consumption in 2015 included 2.1 million tons of biodiesel, 1.2 million tons of bioethanol, 50 million cubic metres of biomethane as well as approximately 2,000 tons of vegetable oil.
The German agricultural and biofuel sector is committed to sustainability and seeks to ensure constant improvements in the greenhouse gas balance of biofuels. Average greenhouse gas emissions from biofuels in 2015 were over 70% lower than emissions from diesel or petrol. Utilisation cascades and exploitation of co-products enable an optimum combination of food production, supply of biofuel feedstocks and materials utilisation. Prime examples include the rapeseed-biodiesel-rapeseed meal or sugarbeet/grain-ethanol-DDGS production pathways. Co-products from processing of cultivated biomass for biofuels play a significant role in domestic supply of protein feed, making a sizeable contribution to value creation in rural regions. Increased use of residues and by-products may complement such biofuels but cannot serve as a substitute for them.
The EU-Commission Proposal (RED II)
The draft Directive of 30.11.2016 envisages switching to what are known as advanced renewable fuels in the transport sector by means of a minimum quota. Biofuels from agricultural biomass (referred to as conventional biofuels) may not be counted towards this quota. Instead these conventional biofuels are only taken into account in the context of calculations relating to the overarching EU goal for renewable energies, up to a ceiling of 3.8% of total energy use in the transport sector. The Commission's plans do not envisage continued pursuit of the implementation strategy adopted in Germany, which entails a non-technology-specific obligation to reduce GHG emissions in the mobility sector (pursuant to the Fuel Quality Directive).
Appraisal of the EU-Commission Proposal
The following amendments to the proposed draft Directive (RED II) are urgently needed: