eu sustainability scheme for biofuels: differences between national systems
TRANSCRIPT
EU sustainability scheme for biofuels: differences between the national systems
Fuels of the Future 2015, Berlin
Gemma Toop
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Member State biofuel target progress
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Source: Ecofys 2014
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Progress towards the target for EU as a whole
> 5.11% renewable transport in the EU as a whole in 2012
– Of which 3.4% sustainable biofuels & 1.25% double counting
biofuels (remainder renewable electricity)
> Increase compared to 3.41% in 2011
> But decrease compared to 4.84% in 2010 and 4.31% in 2009
> So are we on track for 2020?
> Big questions to be answered regarding ILUC proposal, cap on
conventional biofuels, double counting, sub-target for advanced
> Many Member States not confirmed level of national mandates
out to 2020
> But underlying statistics for 2009-2012 suggest that total biofuels
consumption increased, especially double counting biofuels
> The decrease in 2011 caused by biofuels being not compliant with
the sustainability requirements of the Directive, or failing to
demonstrate compliance
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What do we mean by a ‘national system’?
> RED foresees 3 ways for economic operators to demonstrate
compliance with the mandatory sustainability requirements (COM
2010/C 160/01):
1. “By providing the relevant national authority with data, in
compliance with requirements that the Member State has laid
down (a ‘national system’);
2. By using a ‘voluntary scheme’ that the Commission has
recognised for the purpose;
3. In accordance with the terms of a bilateral or multilateral
agreement concluded by the Union with third countries and
which the Commission has recognised for the purpose.”
> Most national systems now implemented, but still some delays
> First 7 voluntary schemes recognised by EC in July 2011. As of
September 2014, EC recognises 19 voluntary schemes
> No bilateral or multilateral agreements concluded to date
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What could a national system look like?
“By providing the relevant national authority with data, in
compliance with requirements that the Member State has laid down
(a ‘national system’);”
The national systems we see can be categorised into several types:
1. Those that only allow the use of recognised voluntary schemes
● E.g. Germany, Netherlands
2. Systems based on independent (ex-post) verification of
information provided by economic operators
● E.g. UK, Ireland, France
3. Those that link compliance with the RED requirements within a
country to the Common Agricultural Policy requirements or other
national land zoning approaches
● E.g. Austria, Hungary
Note that all national systems allow the use of EC-recognised VS
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Some examples…
> Germany
– Allows both EC-recognised and some nationally-recognised
voluntary schemes
– Reporting into NABISY database system
> UK
– Economic operators can use EC-voluntary schemes or they
can report an independently verified GHG value and
information on the land-use in January 2008
– Detailed guidance provided for economic operators
> Austria
– Imported biofuels have to comply with a voluntary scheme or
recognised national system (DE, SK, HU, CZ)
– Compliance of domestic feedstock with sustainability criteria
checked as part of CAP requirements with self-declarations
from farmers. Annual field visits conducted by Agrarmarkt
Austria (AMA) on a sample basis to monitor compliance
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Do different approaches lead to differences in
effectiveness and administrative burden?
> National systems that offer different options to demonstrate
compliance very helpful in early years, especially when there were
no EC-recognised voluntary schemes
> Most Member States (21) offered some alternative way to
demonstrate compliance at first and/or a transition period with
lighter requirements
> Differences between national systems hinder market liquidity
– E.g. what companies asked to report, recognition of different
voluntary schemes, reporting to more than one administrative
body / additional actors in the supply chain having to report
information
> But most important for effectiveness is that MS implement on
time and offer clear guidance for companies
> Other factors (e.g. mandate certainty, approach to double
counting, whether quotas are restricted to certain companies)
make more difference to level of consumption of biofuels
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Market appears to prefer voluntary scheme
approach
> Early in 2011, it was complex to demonstrate compliance with the
Directive
> This improved in July 2011 the EC recognised the first 7 voluntary
schemes. Now 19 voluntary schemes have been recognised.
> Now strongly see the market moving towards voluntary schemes
– UK RTFO Year to April 2014 (provisional) data shows 99% of
biofuels supplied under a VS, up from 81% in previous year
and 40% year before (Dec 11 - Apr 12)
> Ex-post verification puts all costs of compliance on end fuel
suppliers / obligated parties
> Voluntary schemes spread the cost of compliance through supply
chain – but is it more expensive overall?
> Voluntary schemes offer up-front guarantee of compliance in any
Member State
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Concluding remarks
> Design of national system is important, but other factors can
make a bigger difference to amount of biofuels deployed
– Double counting, mandate certainty etc
> Most economic operators are opting to use voluntary schemes,
because of up-front guarantee of compliance in any Member State
> Member States can help by offering clear and practical national
systems, whatever the design
– Providing clear guidance and a service to answer questions
– Reporting to one central authority in the Member State
– Offering standard reporting templates / database systems
– Avoiding delays in implementation
> Dialogue with other Member States (e.g. REFUREC) important to
work together to spot issues and increase understanding of other
national systems as a step towards more streamlined
implementation
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Thank you for your attention!
Gemma Toop
+44 (20)7423 0977
Ecofys UK Ltd
1 Alie Street
London E1 8DE
www.ecofys.com
Gemma Toop