Fachverband Biogas e.V. - German Biogas Association

Generally, we support all measures aimed at reducing climate change and promoting alternative energy sources. Meeting the EU's 2030 target of at least 40% renewable energy in the EU's gross final energy consumption is a step in the right direction. However, there are several stipulations that we would like to see amended, we will address in detail in the following. 1.

The European Union’s commitment to meeting the Paris climate targets and achieving climate neutrality by 2050 will have to lead to major policy adjustments in the next years. In line with the revision of other key framework legislation in the so-called Fit for 55 Package, the revision of the Renewable Energy Directive (RED III) is of key importance for our common ambition.

The German Biogas Association welcomes the EU's ambition to revise the Renewable Energy Directive's goals. The German Biogas Association thinks it very necessary to align the different legislative acts and thus votes for option 5. Binding targets are needed in order to accelerate the greenhouse gas emissions reduction and to ensure that renewable energy is deployed across all sectors throughout Europe.

The German Renewable Energy Federation (BEE) welcomes the COM proposal to reduce GHG emissions by at least 55 percent by 2030. In order to be able to achieve an ambitious greenhouse gas reduction target of at least 55 percent by 2030 compared to 1990, an equally ambitious increase in the targets for the share of renewable energies in gross final energy consumption and energy efficiency are necessary.

The German Biogas Association (GBA) welcomes the opportunity to comment on the Commissions public consultation on the revision of the packaging and packaging waste directive. The GBA supports the efforts of revising this directive as it contributes to a circular economy and helps reaching some of the goals outlined in the EU Green Deal and the Zero Pollution Action Plan.

The German Renewable Energy Federation (BEE) welcomes the European Commission’s proposal for a European Climate Law as part of the “European Green Deal”. In this context we value the proposal that all legislative proposals should be subject to a “Climate Consistency Assessment” in order to evaluate their conformity with the goal of greenhouse gas neutrality.

The German Biogas Association welcomes the proposal of an European Climate Law within the European Green Deal. However, the contents are disappointing so far. A strong framework and trajectory for accelerated use of renewable energies in all end-use sectors, for phasing out all fossil fuels and clear incentives for investments in a greenhouse gas-neutral industry are missing.

The German Biogas association (FvB) welcomes the European Commission’s (EC) initiative for a European Climate Law to legally establish the objective of climate neutrality by 2050 and to provide rules to ensure that all policies of the EU institutions and of the EU Member States (MS) contribute to such a goal. The climate law must define climate neutrality clearly.

The German Renewable Energies Federation (BEE), the umbrella of the German renewable energies sector, welcomes the European Commission’s (EC) initiative for a European Climate Law to legally enshrine the objective of climate neutrality by 2050 and to provide rules to ensure that all policies of the EU institutions and of the EU Member States (MS) contribute to this commitment.

The German Renewable Energy Federation (BEE) welcomes the COM proposal to reduce GHG emissions by at least 55 percent by 2030. In order to be able to achieve an ambitious greenhouse gas reduction target of at least 55 percent by 2030 compared to 1990, an equally ambitious increase in the targets for the share of renewable energies in gross final energy consumption and energy efficiency are necessary.

In principle, the orientation of the ETD towards climate protection is welcomed, as it puts an end to the preferential treatment of fossil energy sources. However, there are some details to address in more clarity. 1. Definitions of categories There are no clear definitions within the Directive.

The German Biogas Association welcomes the European Commissions proposed target to reduce greenhouse gas emissions by 90% by 2040 compared to 1990 levels. However, the option to meet up to 3% of the target via international carbon credits from 2036 onwards weakens the domestic focus of EU climate policy and raises concerns around oversight, additionality, and certification.

Stellungnahme 22. Juni 2022 Vorschlag für eine Richtlinie des Europäischen Parlaments und des Rates zur Änderung der Richtlinie 2010/75/EU des Europäischen Parlaments und des Rates vom 24. November 2010 über Industrieemissionen (integrierte Vermeidung und Verminderung der Umweltverschmutzung) und der Richtlinie 1999/31/EG des Rates vom 26. April 1999 über Abfalldeponien (IE-Richtlinie) Der Fachverband Biogas e.V.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The proposal's main focus is set towards the "CO2 emission standards for passenger cars and light commercial vehicles" by "boosting the uptake of zero emission vehicles and related infrastructure" [p. 2]. In general, the German Biogas Association supports this approach, especially since at first sight "decarbonisation" of electricity production and renewable as well as low-carbon fuels shall be supported.

The Biogas Association welcomes the European Commission’s plans to reduce emissions from the transport sector by 90 % by 2050. However, in order to achieve this objective, it is necessary to move from the already established ‘tail-pipe’ approach, which considers only emissions from fuel combustion, to a ‘well-to-wheel’ approach that takes into account the pre-chain emissions of fuels.

Filed in German · English published by the European Commission

The German Biogas Association (GBA) welcomes the fact that the EU Commission wants to regulate, facilitate and expand market access for renewable gases – including hydrogen – in the common market. However, in the draft proposal there is no distinction made between renewable, low-carbon or fossil-based gases.

Although the Regulation on Alternative Fuels Infrastructure (AFIR) refers to directives like the Clean Vehicle Directive (CVD) and suggests to be in consistency with it, the German Biogas Association sees some contradictions or omissions. Whilst the CVD explicitly states the necessity of (Bio-) C/LNG infrastructure, this is not properly reflected in the AFIR.

In principle, the orientation of the ETD towards climate protection is welcomed, as it puts an end to the preferential treatment of fossil energy sources. However, there are some details to address in more clarity. 1. Definitions of categories There are no clear definitions within the Directive.

In general, we welcome the inclusion of RENURE fertilisers in the current draft Nitrates Directive. However, the Commission proposal deviates from the technology neutral approach outlined in the original Joint Research Center (JRC) study.

Filed in German · English published by the European Commission

The German Biogas Association (FvB) welcomes the European Commissions proposal for a Regulation on the accounting of greenhouse gas emissions of transport services, which sets a common regulatory framework for GHG emissions.