CC(22)3328:1 – PPA/IDT/DDJ/na To:
Ministers of Energy
Ministers of Environment
Copy:
Members of the COREPER I
Brussels, 22nd June 2002
Re: Fit for 55 package - Copa and Cogeca’s priorities in view of the Energy and
Environment Council meetings of 27 and 28 June 2022
Dear Minister,
In view of the discussions and possible agreements on “general approach” on the agenda of the
next Energy Council of 27th June and Environment Council of 28th June, on key dossiers of the
Fit for 55 package we would like to bring to your attention Copa and Cogeca contribution.
We are committed to making the EU climate neutral by 2050, by reducing our emissions,
producing biofuels, bioenergy, and bio-based materials for other industries, and by increasing/
maintaining the carbon sink that agriculture and forestry can represent by optimising CO2
absorption of ecosystems while replacing fossil fuels. Nevertheless, the production of food (incl.
feed) remains a central factor, as per Article 2 (b) of the Paris Agreement. This is even more
fundamental in the context of the consequences for the global food supply chain of the Russian
invasion of Ukraine.
The initiatives under discussion propose profound changes and major investments that will
redefine our agricultural model for the decades to come. On the ground, European farmers are
engaged in these multiple transitions which if not properly and coherently framed, risk having
severe consequences on food security, food affordability and the farmers’ income together with
the long-term viability of European farmers and cooperatives.
Copa and Cogeca would like to propose the following priority considerations on the proposals to
be discussed:
1. Revision of the Renewable Energy Directive
Greenhouse gas emissions saving will deteriorate considerably as a result of the war in
Ukraine because several Member States will have to use coal-fired power
plants to reduce gas consumption to generate electricity.
Copa and Cogeca recommend a stable, long-term policy guaranteeing the
existing and future investments in the bioenergy sector as well as greater
consistency between the different EU policies in which certified crop-based biofuels are
by far the most important option in the European Union to reduce greenhouse gases in
transport.
Regarding the decarbonization of transport, Copa and Cogeca:
Regret the lack of ambition on the target and the reestablishment of all
multipliers; we recall that transport emissions must be compensated by higher savings
in other sectors such as agriculture.
Welcome the Council general approach to offer Member States the
flexibility to also pursue decarbonization of the transport sector with a renewable
energy incorporation obligation as provided for in Directive (EU) 2018/2001.
Copa - Cogeca | European Farmers European Agri-Cooperatives
61, Rue de Trèves | B - 1040 Bruxelles | www.copa-cogeca.eu
EU Transparency Register Number | Copa 44856881231-49 | Cogeca 09586631237-74
Support strengthening the role of biomethane as advanced biofuels.
However, regret that the Council has not supported greater flexibility
regarding the 7% cap set in Article 26 of Directive (EU) No 2018/2001 for certified
crop-based biofuels to leave to each Member State a certain amount of room for
maneuver. The Council has supported the Commission’s proposal on the revision of
GHG saving methodology, detrimental to crop-based and advanced biofuels.
Consider that the Council could have been more ambitious by increasing the
obligation to reduce the carbon intensity of fuels for transport according to an
indicative trajectory, starting with 6% in 2021, as laid out in the Fuel Quality Directive,
to at least 20% in 2030 in order to guarantee the continuity of efforts to decarbonise the
transport sector, pooling the 7% cap on crop-based biofuels at EU level, removing of all
multipliers, maintaining unchanged the GHG savings methodology for
biofuels and bioliquids. In this respect:
o The abolition of the NUTS2 system eliminates simplification, adding
further administrative burden to exploit the existing resource
potential.
o If the proposed changes in the methodology of the greenhouse gas
saving regarding carbon capture and replacement (CCR) were adopted,
carbon captured and used will be released back into the atmosphere in the
future. EU biorefineries would no longer be able to claim GHG savings
from CCR. This would have serious impacts the biofuel industry and
investments made but also on the GHG performance of ethanol. Copa and
Cogeca oppose the Commission and the Council general approach
regarding the changes in the GHG saving methodology.
o The minimum greenhouse gas reduction threshold should remain
unchanged at 65% for liquid biofuels and gases, bioliquids and gaseous fuels
derived from biomass. Copa and Cogeca are against introducing retroactive
thresholds for GHG reductions for heating, cooling and electricity generated
from biomass. The 80% threshold should only apply to installations that start
operation in 2028 or later. Retroactive application of the complex calculation
method for GHG emissions savings have been proposed, which poses a threat to
investments already made and current commercial decisions.
Regarding solid biomass from forest, we welcome the Council general
approach that consists in a step in a direction, which is more compatible with the
sustainable management of forest.
Ask for off-grid biogas to be counted towards the overall renewable energy
target. This is key for agri-biogas, because there is no transmission network in most of
EU rural areas. This approach would support the implementation of RePowerEU and
definitely have impact on the willingness to support biogas with national programmes.
Also draw the attention to the energy communities, legal bodies which have the
potential to broaden smart grids over rural areas. It is important to let the energy
community shareholders to be able to sell the energy produced to the national power
grid operators, in order to incentivize people to join energy communities and to deploy
more and more renewables power to the European grids.
2. Land use, land use change and forestry (LULUCF)
While reiterating the need for a market-based certification scheme for carbon uptakes/removals
we call for:
Support towards maintaining the AFOULU (Agriculture, Forestry and Other Land
Use) framework also after 2030.This compromise proposal with the elimination of
the 2035 neutrality objective, whilst maintaining the AFOULU also after 2030,
would allow to integrate progressively the land-based sector with a cost effective
mitigation effort.
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Support for the Commission proposal to set out a process at EU level for post
2030 over introducing already now targets.
Non-CO2 agriculture emissions to be included under the commitments to ensure
the collective achievements of climate-friendly policies under the LULUCF.
LULUCF-Effort Sharing Regulation flexibilities which should reflect the AFOLU’s
synergic relationship, prioritizing flexibilities between agriculture and
LULUCF sectors.
3. CO2 emission standards for cars and vans
The proposed revised regulation is a missed opportunity to establish the
principle of technology neutrality and recognize the cost-efficient role of certified,
sustainable, crop-based and advanced biofuels such as biomethane.
The Commission’s proposals can be corrected by introducing elements of a
wider Well-to-Wheel approach with a methodology that takes account of the
nature of energy for powering vehicles, distinguishes between fossil and biogenic
CO2 and accounts for the full life cycle of electricity generation, including production
and recycling of batteries.
An appropriate accounting mechanism for certified crop-based and advanced
biofuels that will incentivise the vehicle industry to further invest in cost-effective and
available solutions like higher biofuel blends and biomethane. The methodology must be
comprehensive and fair to properly evaluate each alternative. There is no “zero
emission” technology, even for electric mobility
Finally, Copa and Cogeca welcome the proposal of establish the Social Climate Fund
(SCF) which aims to support measures and investments to ‘benefit vulnerable households,
micro-enterprises or transport users, and increase the energy efficiency of buildings,
decarbonisation of heating and cooling of buildings, integration of energy from renewable
sources, as well as access to zero and low-emission mobility and transport’. This will be crucial
particularly if the current drastic context of increasing production costs for farmers (i.e. feed,
fertilisers, energy) continues in the long term.
The Fit for 55 Package is an opportunity to bring about a fair cross-sector approach in EU
climate and agricultural policy. We need to use all policy tools available at EU level to make sure
that the pace of change is sufficient, but not overly disruptive for the farming community. We
need a fair transition, in which sustainability can be improved. However, this must be done in a
manner that strikes a balance between the economic, environmental, and social dimensions so
that does not leave anyone behind – especially farmers.
You will find also attached the adopted Copa and Cogeca horizontal position on the Fit for 55
package.
We count on your assessment to take into consideration our proposals and stand ready to
further contribute to the discussions to find the best solutions in the interest of the European
farming and cooperative community.
Yours faithfully,
Pekka Pesonen
Secretary General
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Saatja: Natalia Alexei <
[email protected]>
Saadetud: 22.06.2022 16:56
Koopia: Pekka Pesonen <
[email protected]>; Patrick Pagani
<
[email protected]>
Teema: Fit for 55 package - Copa and Cogeca’s priorities in view of the
Energy and Environment Council meetings of 27 and 28 June 2022
Dear Minister,
Please find attached Copa and Cogeca letter in view of the Energy and
Environment Council meetings of 27 and 28 June 2022.
Thanking you for your consideration.
Kind regards,
On Behalf of Pekka Pesonen
Secretary General
Natalia Alexei
Assistant of the Secretary General
Copa and Cogeca
Rue de Trèves 61
1040 Brussels
Tél: +32(0)2 287 27 32