Αρχική ΕΚΣΥΓΧΡΟΝΙΣΜΟΣ ΤΗΣ ΝΟΜΟΘΕΣΙΑΣ ΓΙΑ ΤΗ ΧΡΗΣΗ ΚΑΙ ΠΑΡΑΓΩΓΗ ΗΛΕΚΤΡΙΚΗΣ ΕΝΕΡΓΕΙΑΣ ΑΠΟ ΑΝΑΝΕΩΣΙΜΕΣ ΠΗΓΕΣ – ΕΝΣΩΜΑΤΩΣΗ ΤΩΝ ΟΔΗΓΙΩΝ ΕΕ 2018/2001 ΚΑΙ 2019/944Άρθρο 40 Κανόνες υπολογισμού σε σχέση με τα ελάχιστα μερίδια ενέργειας από ανανεώσιμες πηγές στις μεταφορές – Προσθήκη άρθρου 32ΣΤΓ στον ν. 3468/2006Σχόλιο του χρήστη Angel Alvarez Alberdi (EWABA Secretary General) | 24 Φεβρουαρίου 2023, 14:19
  • Σχόλιο του χρήστη 'Angel Alvarez Alberdi (EWABA Secretary General)' | 24 Φεβρουαρίου 2023, 14:19

    EWABA COMMENTS REGARDING ARTICLE 40 OF THE GREEK LAW FOR THE TRANSPOSITION OF DIRECTIVE 2018/2001/EC UNDER PUBLIC CONSULTATION According to Article 27 par. 2(a)of the Directive 2018/2001/EC (known as the “REDII”) “The share of biofuels and biogas for transport produced from the feedstock listed in Annex IX may be considered to be twice its energy content”. This specific measure, known as “double counting”, was designed by the EU legislator to promote the use of biofuels from certain feedstocks whose qualities (higher sustainability, waste and residual nature, greater decarbonization potential, etc.) made them worthy of extra promotion. The double counting mechanism also addresses the fact that these feedstocks are more difficult and costly to collect, pretreat and process than conventional crop-based feedstocks, thus making a policy promotion mechanism necessary for the production of waste-based and advanced biofuels. The word “may” in the text of the European Directive, concerns only the discretion of each Member State to enact the double counting mechanism in their national legislation, according to its internal policies and priorities. In this context it cannot be interpreted as a provision allowing Member States to leave this matter open and decide at a later date whether the mechanism is applicable in the national legislation or not. Indeed, the double counting mechanism is currently enshrined in the national legislation of the vast majority of the EU Member States, namely: Belgium, Croatia, Cyprus, Czech Republic, Denmark, Estonia, France, Hungary, Ireland, Italy, Latvia, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia and Spain. It is also applied in the UK and Norway. The Greek legislator approach to keep the exact same wording as in the Directive goes against the Directive’s objective, which is in fact the conferral to Member States of the power to decide on whether to include double counting or not in the transposing legislation. Greece is therefore avoiding taking a clear position regarding the application of this much needed mechanism. On the other hand, by leaving the matter open to future application it creates a legislative gap regarding whether double counting will apply in Greece or not at which time and under which specific circumstances it shall be applied. In implementing the REDII the Greek legislator has chosen to promote renewable electricity for transport with multiple counting. The wording in the text of the Directive, which is in the next paragraph of Article 27, was the same as with double counting for Annex IX, yet the Greek proposal is to necessarily apply multiple counting to electromobility (by using “shall” instead of “may”). Electromobility is indeed needed and worthy of public promotion by the legislator. So are Annex IX biofuels, whose decarbonization potential (up to 90% GHG reduction) and circular economy properties made them a particularly powerful tool to significantly reduce emissions the road (especially heavy-duty), maritime and aviation sectors. For all the above-mentioned reasons we propose amending the wording of article 40 of the Greek law which transposes Article 27 of the REDII from: •The share of biofuels and biogas for transport produced from the feedstock listed in Annex IX may be considered to be twice its energy content to •The share of biofuels and biogas for transport produced from the feedstock listed in Annex IX shall be considered to be twice its energy content Many thanks for your consideration of our request. About EWABA EWABA is a Brussels-based association representing the interests of the European waste-based and advanced biofuels industry before EU institutions, national governments, industry, civil society and the media. We promote the inclusion of waste-based and advanced biofuels in the EU fuel mix as a sustainable means of reducing greenhouse gas emissions in EU transport. Our +40 members active in most EU Member States collect and use waste and advanced feedstocks listed in parts A and B of Annex IX of the Renewable Energy Directive (REDII) to produce sustainable biodiesel with the highest GHG savings (up to +90%) when compared with fossil fuels, thus enabling “near-term decarbonization” of the EU road and maritime transport sectors. www.ewaba.eu