Posted September 23, 2009

Those responsible for implementing the European Commission's Fuel Quality Directive and Renewable Energy Directive are currently evaluating modeling of indirect land use (ILUC) and are planning to present policy alternatives for public comment this fall, with a goal of announcing the final policy in the spring of 2010. Ariane de Dominicis said it is still undetermined just how ILUC will be treated, although direct land use change will be addressed in the sustainability criteria for eligible fuels.

Dominicis and Wojciech Winkler spoke about implementation of the EU renewable fuel policies at a Sept. 23 Webinar hosted by the International Fuel Quality Center, a nonprofit facilitated by Hart Energy Consulting. Winkler assisted in the Fuel Quality Directive's legislative process and is presently responsible for its implementation. Dominicis is coordinating biofuels policies. Both work at the Directorate General for Environment of the European Commission.

The EC's Fuel Quality Directive calls for a 6 percent life cycle analysis greenhouse gas (GHG) intensity reduction between 2010 and 2020 for all transport fuels. Additional biofuels sustainability criteria call for a direct GHG savings threshold of 35 percent now for biofuels, rising to 50 percent in 2017 and 60 percent in 2018 for new installations.

According to the preliminary default GHG ratings shown in the EC presentation, that will present a challenge for all but waste-based biodiesel feedstocks. Rapeseed biodiesel's current default GHG savings value of 38 percent is eligible only for the first years of the program; soy biodiesel at 31 percent is not. Palm oil rated 56 percent if methane emissions at processing facilities are dealt with, and only 19 percent if methane is not mediated. Waste-based biodiesel scored above 80 percent in GHG reductions. Emissions can be reported using either the default values, Dominicis said, or actual values can be used, a policy that should create incentives to improve GHG reduction performance for different fuel pathways. The regulations also include a provision that default values and GHG methodology can be updated when new science or evidence is available or new fuel pathways created, she added.

Direct land use change is addressed in the EC policy by prohibiting eligible biofuels from the conversion of high carbon stock areas such as wetlands, continuously forested areas or undrained peatland. While the permanent conversion to cropland is prohibited, Dominicis added, the biomass from that land could be used. "You could use the forest, but you can't clear the forest and convert it to cropland," she said. Guidelines on how to identify such areas also are being developed now, she said.

Dominicis said the indirect land use issue is being studied now by the EC in two tracks. One group is examining the current science while another is exploring possible policies. She gave no hints whether indirect land use will ultimately be incorporated into the EC policy. While the EC directive said a policy determination should be in place by the end of 2010, the internal goal is to have that determined by the spring of 2010 following another round of public comment this fall.

Winkler addressed the fossil fuel component of the Fuel Quality Directive in the Webinar. A system to collect national fuel quality data is being developed, he said, along with a system for monitoring compliance, including specifying the appropriate analytical methods. The system will allow some flexibility, he added, mentioning the potential for special specifications for states with low ambient temperatures as an example.

The directorate of the environment is also working on the methodology to determine non-biofuel GHG emissions as well as determining the baseline value for the fuel mixture used in 2010. The goal is to develop technology neutral approaches to achieving a 6 percent reduction in carbon intensity for suppliers of energy used in road transport and non-road mobile machinery between 2011 and 2020. That will require developing a baseline GHG value for the fuel mix used in 2010. Winkler added that some studies have indicated that to achieve those sorts of carbon reductions in the next decade, the EU will see a change in the ratio of diesel used to gasoline that approaches 50/50, compared to the current ratio where 65 percent of the fuel used in the EU is diesel, and 35 percent gasoline.

To learn more about the EU renewable energy policy development visit: http://ec.europa.eu/energy/renewables/index_en.htm.