Answer to Public Consultation on Annex V and VI of RED III
Answer to Public Consultation on Annex V and VI of RED III
Bioenergy Europe welcomes the opportunity to provide feedback on the proposed revision of the Greenhouse Gas (GHG) emission saving methodology under Annex V and VI of the Renewable Energy Directive (REDIII). Yet, some critical issues require urgent clarification and adjustment.
While we support the Commission’s efforts to update the framework, by including previously missing segments such as the accounting of permanent carbon storage (BECCS) and default values for Fischer-Tropsch, we have identified critical issues in the proposed methodology that require urgent clarification and adjustment.
Sustainable bioenergy is a core pillar of the EU’s climate mitigation efforts and makes a significant contribution to European security of supply, providing almost 11%1 of the EU’s energy consumption. The proposed changes in Annex VI will directly affect solid biomass pathways in both existing and planned infrastructure and jeopardising the achievement of the EU 2040 and 2050 targets.
The main concerns lie in:
- Unjustified increases of disaggregated default values vs. typical values for forest biomass fuels supply chains.
- Issues with the introduction of Moisture Content Reference Values in the legal text
- Issues with the introductory paragraphs before Tables A.1 and A2.
- Provide more flexibility for electricity emission intensity in processing emissions
- Reconsider the introduction of the Cstor factor for biomass storage
- Provide increased flexibility in using default values for a wider range of feedstock
