The Advanced Biofuels Coalition (LSB) welcomes the opportunity to provide feedback on the Inception Impact Assessment on a 2030 Climate Target Plan. LSB welcomes EU’s increased commitment to combatting climate change. LSB especially welcomes an increased dedication to reduce transport emissions.

LSB is a coalition of leading advanced biofuel technology developers and producers committed to making a significant contribution to meeting the EU ambitions of decarbonizing the transport sector. Sustainable advanced biofuels are a fast track solution for decarbonizing transport. Advanced biofuels bring multiple benefits in terms of CO2 reduction, investments, revenues for farmers and forestry, improved waste management practices, job creation and an increase in energy security.

Advanced biofuels development in the EU was lagging behind from 2012 until 2018 due to a lack of policy certainty due to negotiations on revisions of the Renewable Energy Directive (ILUC and RED II). Finally, in December 2018 the REDII was adopted. Since then considerable investments in advanced biofuels manufacturing have been made and progress in building-up of production capacity is under way. The REDII with its binding mandate sets the right direction enabling advanced biofuels to contribute to the decarbonization of EU transport. This direction must not be endangered.

Considering both the urgent need to act on climate change and the economic challenges stemming from the current COVID-19 situation, regulatory certainty for investments in climate technologies is of immense importance. The potential proposal of regulatory changes would have wide-ranging impacts. Therefore, measures must be taken with a transparent process as not to jeopardize on-going or future investments.

LSB also calls for a swift implementation of existing directives. EU member states must not deviate from the agreed targets, such as for advanced biofuels as defined by REDII Annex IX part A, while a potential revision of the target levels is undertaken. LSB underlines that a binding mandate is the most effective measure to bring advanced biofuels to the market. Introducing road transport into the ETS could be counterproductive.

LSB will provide further input to the Commission public consultation in due course.

https://www.advancedbiofuelscoalition.eu/wp-content/uploads/2020/04/200415-LSB-contribution_IIA-on-2030-targets-plan_final.pdf