CEMA submission to EU consultation on sustainable bioenergy policy after 2020
New policy should support direct on-farm production & use schemes of bioenergy
3 key mesages from CEMA's submission on EU bioenergy policy (to read the contribution in FULL, please click on the document link below):
1. Promote the use of bioenergy in agricultural machinery
Several new innovative models already exist to power agricultural machines with bio-based energy produced directly in a decentralized manner on the farm. Apart from significant GHG emission reductions, such schemes have multiple secondary benefits for farmers and the world of agriculture such as:
- turning farmers into energy providers;
- providing farmers with valuable additional income streams;
- helping to bridge the gap that Europe has in locally sourced high-protein animal feed
- Reduction of Europe’s dependency on fossil fuel imports
- Stimulation of jobs, regional development, and rural industry in Europe
Plant-oil powered tractor: certain tractor models today can already drive with either diesel, biodiesel, or pure plant oil. The machine automatically recognizes the fuel and the electronic control unit of the engine reacts accordingly so as to comply with the strict EU engine emission standards for off-road vehicles. Certain plant oil such as rapeseed oil is widely available across Central Europe and can often be sourced on the farm itself. Rapeseed plants not only provide food for the tractor but also feed for animals. Only one third of the rapeseed is made up of oil, the remaining two thirds can be turned into rapeseed press cake which is purely made up of vegetable protein and thus presents an equivalent alternative to soy feed. In other countries and continents, sun flowers, soy or cotton could be used in a similar way. In the case for Germany, for instance, 1.6 million tons of diesel are used each year for agricultural purposes, around 5% of the overall consumption. If this amount was to be replaced by rapeseed oil, 1.5 to 1.8 million hectares of arable land would be required for rapeseed, around eight to ten percent of total arable land.
Biogas-powered tractor: prototypes for methane-powered tractors have been developed. The methane can be generated through renewable biomass produced in a biogas plant available on the farm. Methane propulsion technology offers various environmental advantages including emissions 80% lower than a standard diesel engine. When using bio-methane, the machine’s carbon impact is virtually zero, and cost savings between 25% and 40% can be achieved when compared with conventional fuels.
2. Methodology behind EU sustainability criteria should use 'substitution allocation' methodology instead of allocation methodology by energy content
EU sustainability criteria need to avoid an undifferentiated ‘one size fits all approach’ approach to biofuels and leave sufficient space for the development of new innovative models for the production and use of bioenergy. It will be essential that different schemes of bioenergy production and use are adequately assessed in a sufficiently holistic way in order to determine their respective risks, benefits, and opportunities. This should include that the current allocation methodology – allocation by energy content – to by-products be replaced by the “substitution allocation methodology”. The current allocation methodology – allocation by energy content – to by-products carries the inherent risk that it does not provide adequate insight in effects of by-product utilization on GHG emissions, and thus does not adequately reward (or penalize) different types of by-products utilization. This may lead to significant errors in the final assessments. The model should be replaced by the “substitution allocation methodology” because it would allow a better CO2 emissions calculation and the results would be much different. Take for instance, the case of the residual rapeseed cake considered a ‘by product’ of rapeseed oil to be used in e.g. agricultural machinery. The current methodology only considers the energy burning equivalent value of the cake, yet fails to consider that the high-protein cake is normally used as high-value animal feed and thus leads to considerable GHG emissions and sustainability benefits (soil health, anti-erosion effects due to permanent coverage, natural fertilizer effect of plant residue, nitrogen fixing etc.), particularly when replacing protein feed imported from overseas.
3. Use tax policy & the CAP to promote research in & uptake of innovative bioenergy technologies in farm production processes
Future funding schemes for research in and uptake of innovative bioenergy technologies will be of critical importance to ensure such schemes are being developed and used in farm production processes. For the purchase of plant-oil based tractors, various regions in Germany have devised dedicated tax-deduction schemes. Such schemes should be complimented by new investment mechanisms for sustainable bioenergy-related production tools to be included in the EU’s Common Agricultural Policy (CAP). As regards research into alternative, bio-based energy provision models for agricultural machinery, further funding should be made available under the EU’s Horizon 2020 Programme.