Finnish Biocycle and Biogas Association contribution to the consultation on the CO2 standards – Inception Impact Assessment

CO2 emissions for cars and vans – revision of performance standards (europa.eu)

Finnish Biocycle and Biogas Association welcomes the efforts of the European Commission to revise the existing legislation to achieve a new 2030 target and the climate neutrality objective by 2050. Despite all the current efforts at the EU level, the greenhouse gas emissions are not decreasing in the transport sector.

The revision of CO2 vehicle standards is very crucial to ensure a fast, safe and affordable transition to smart and sustainable mobility. As mentioned in the roadmap, the CO2 vehicle standards have proven to be an effective policy tool but without further policy intervention, emissions from road transport are not projected to meet the targets set. It is clear that leveraging on the CO2 emissions reduction only at tailpipe level has not been sufficient enough to ensure the shift to carbon neutral mobility.

One of the bottlenecks is that the current CO2 vehicle standards on passenger vehicles and vans prevents Europe from exploiting the full potential and advantages of biomethane in transport. This is entirely inconsistent with the scientific findings, which are clear: biomethane represents one of the absolute lowest greenhouse gas intensive options applicable to decarbonization of road transport. The current CO2 emission standards are also contradictory to the revised Renewable Energy Directive setting a favourable framework for the uptake of biomethane in transport.

The revision aims at increasing interlinkages between energy and mobility sectors. However, we see that this will not happen unless the role of biomethane is strengthen in the context of the revision.  The potential of renewable gases has been recognized widely in the EU policies and at national levels. Biomethane is renewable gas that is widely available already now.  It takes time before other renewable gases are widely in use. The biomethane paths the way to the other renewable gases, because the same gas infrastructure can be used.

It is also important to recall the wider cross sectorial role of biomethane that can help in reduce emissions to air, water and land from various sectors namely agriculture, waste management, energy production, industry and transport. Biomethane production is at the heart of an efficient circular economy: it is the best way to recycle organic waste, to produce valuable renewable gas and biofertilizers. The potential of biogas and biomethane has pointed out in the several policy papers published by the European Commission in 2020 such as in a Farm-to-Fork strategy, EU methane strategy and a new Circular Economy Action Plan.

We call on the European Commission to eliminate the regulatory obstacles by taking three constructive measures, all of which fit within the European Green Deal Framework:

  • INCENTIVES FOR OEMS: The carbon credits for gas vehicles can be applied in all member states by adding a following sentence to the article 5 article of the Regulation (EU) 2019/631: [The average TTW emissions of new gas passenger car are calculated as 50 g CO2 /km, but the TTW emissions needs still be under 95 g CO2/km.]
  • INCENTIVES FOR BIOMETHANE PRODUCERS: setting a target for the share of renewable gas (transport) used in the EU by 2035 or other measurement to fasten the development. The target could be set e.g. in the context of the RED 2 revision or the fuel quality directive revision. The average share of renewable gas in the EU is 17%, in Sweden 94% and in Finland 58%.
  • FURTHER INTERGRATING BIOMETHANE TO THE ENERGY AND RESOURCE SECTORAL INTEGRATION: By 2025 the WTW approach is taken into account in addressing eco-efficiency of PCs, LDVs and HDVs. / OR by 2030 a having a new mechanism such as a voluntary CO2-crediting mechanism.

Finnish Biocycle and Biogas Association members produce 70% of Finnish biogas, own 85% of transport gas distribution stations and are responsible for more than 50% of recycled nutrient production in Finland.

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