the voluntary red opt-in for aviation biofuels · in could be implemented into the red legislation....

The voluntary RED opt-in for aviation biofuels Identifying opportunities within the 28 EU member states

Internship Report – Oskar Meijerink

Energy Science

Under supervision of Misha Valk1 Prof. Dr. Martin Junginger2

1 Head of Business Development SkyNRG; Rapenburgerstraat 109 Amsterdam, The Netherlands 2 Professor Bio-Based Economy at Utrecht University; Copernicus Institute of Sustainable Development, Utrecht University

Preface According to the Renewable Energy Directive (RED), each EU member state needs to ensure that, by 2020, 10% of the energy used in the road transport sector comes from renewable energy sources. A recent amendment to the RED (directive 2015/1513, better known as the ILUC amendment), discusses the effects of biofuel production on Indirect Land Use Change (ILUC). This amendment also opens up the opportunity of using Sustainable Aviation Fuels (SAF) to fulfil a member states’ obligation. This so-called ‘voluntary aviation opt-in’ has already been implemented in Dutch legislation since 2013. However, only since the ILUC amendment this option is officially recognized by the EC. Therefore, other EU member states have not yet implemented the voluntary aviation opt-in. This report provides information on how the voluntary aviation opt-in works in the Netherlands and how other EU member states could implement the opt-in into their local RED legislation. This study is executed by SkyNRG in collaboration with Boeing. The importance of creating a level playing field with road transport legislation is widely realised by the aviation industry. Therefore, multiple stakeholders as well as local policy organisations have been supportive in sharing information and discussing the opportunities of the aviation opt-in. This report is structured as follows; the document starts with the executive summary, which is longer than a regular executive summary as it serves as a stand-alone document and is a concise information overview for industry stakeholders and local governments. The summary has five main components:

1. A general introduction on SAF and the opportunity of the RED aviation opt-in. 2. Summary of the Dutch blueprint; this describes the Dutch certificate system including

the aviation opt-in. 3. The member state categorization, as all 28 EU member states have implemented the

RED differently, the potential of implementing the aviation opt-in differs per member state. In this section the member states are categorized according to their aviation opt-in implementation potential.

4. The six high potential member states are further analysed, and an indication of how the aviation opt-in could be implemented in these member states is provided.

5. The summary will be finalised with a review of the results and the possible next steps, taking into account the post-2020 scenarios.

After the executive summary, which only presents the highlights, the different analyses are discussed in more detail. First the full Dutch blueprint, created by SkyNRG is presented. Followed by the EU member state categorization. The document continues with the member state analyses; a conclusion discussion section finalises the report.

SkyNRG 2016 (Document by: Oskar Meijerink)

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Index

Preface ........................................................................................................................................ 2

Abbreviations list ......................................................................................................................... 4

1. Executive Summary .............................................................................................................. 5 1.1. Introduction ............................................................................................................................ 5 1.2. Dutch Blueprint ...................................................................................................................... 6 1.3. EU Member state categorization ........................................................................................... 7 1.4. Member state analysis ......................................................................................................... 10 1.5. Reflection ............................................................................................................................. 16

2. Dutch Blueprint .................................................................................................................. 17 2.1. Introduction .......................................................................................................................... 17 2.2. Aviation biofuel supply chain and regulatory framework for RED opt-in ............................ 18 2.3. From legislation to implementation ..................................................................................... 20 2.4. HBE generation and sales guideline – a blueprint ............................................................... 25 2.5. Conclusion ............................................................................................................................ 28

3. EU Member State categorization ........................................................................................ 29

4. RED aviation opt-in member state analysis ......................................................................... 61 4.1. RED aviation opt-in member state analysis – Spain ............................................................ 61 4.2. RED aviation opt-in member state analysis – Portugal ....................................................... 69 4.3. RED aviation opt-in member state analysis – Ireland .......................................................... 76 4.4. RED aviation opt-in member state analysis – Italy .............................................................. 82 4.5. RED aviation opt-in member state analysis – United Kingdom ........................................... 89 4.6. RED aviation opt-in member state analysis – Germany ...................................................... 96

5. Conclusion and Discussion .................................................................................................. 97

6. References ......................................................................................................................... 99


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Abbreviations list ASTM American Society for Testing and Materials BOS Biofuel Obligation Scheme CIC Certificates of Immission into Consumption CNMC Comisión Nacional de los Mercados y la Competencia CO2 Carbon Dioxide EC European Commission ENMC Entidade Nacional Para O Mercado de Combustiveis EU European Union FQD Fuel Quality Directive GHG Green House Gas GSE Gestore Servizi Eneregetici HBE Hernieuwbare Energie Eenheid (Renewable Energy Certificates) HEFA Hydrotreated Esters and Fatty Acids ILUC Indirect Land Use Change KLM Koninklijke Luchtvaart Maatschappij MS Member State NEA Nederlandse Emissie Autoriteit (Dutch Emission Authority) NORA National Oil Reserves Agency PoS Proof of Sustainability RED Renewable Energy Directive RTFC Renewable Transport Fuel Certificate RTFO Renewable Transport Fuel Obligation SAF Sustainable Aviation Fuels TdB Titulo de Biocombustivel UCO Used Cooking Oil


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1. Executive Summary 1.1. Introduction

The aviation industry is responsible for 2% of anthropogenic CO2 emissions each year. Where other industries can reduce CO2 with e.g. electrification, the aviation industry is bounded to long-term infrastructure and airplanes which will fly on hydrocarbon type fuels for the coming decades. Sustainable aviation fuel (SAF) is the only significant short-term sustainable solution. SAF is physically identical to fossil jet fuel, however made from certified sustainable biomass. Unlike biodiesel, SAF is a so-called drop-in fuel and is therefore fully compatible with existing infrastructure, distribution systems and engines without any modifications. Besides the fact that SAF can be easily blended and used with conventional jet fuel infrastructure, it provides a number of other significant benefits. On an EU level it increases the energy independency. More locally, on a member state level, SAF provides environmental benefits to the surroundings of airports and helps to achieve national emissions targets. Also, airlines benefit from the use of SAF, as they are less bounded to incumbents and can stabilize the current price swings. The development of SAF over the recent past has been substantially. Since the first flight in 2011, more than 1500 flights have been executed on SAF. SAF can be produced with the use of different technological pathways, the current furthest developed pathway, is the HEFA pathway. The fuel produced by using the HEFA process is ASTM approved, which means it can be used in any aircraft under the same rules and regulations as conventional jet fuels. Although technology has been proven to work and airlines are willing to fly on SAF, there is currently limited activity in the production and use of SAF. The main reason for this limited activity is the price gap between fossil and sustainable aviation fuels. SAF is currently, and for the years to come, more expensive than fossil jet fuels. Also, the aviation industry is a very price sensitive industry. As a result, airlines are not able to pay more for their fuel, while keeping competitive. A mechanism to cover the price premium on the short term, should therefore be developed. SkyNRG has been set up in 2009 to make the market for SAF, and has developed several mechanisms to cover the price premium. One of those programs is the KLM corporate biofuel program where corporate customers of KLM pay a price premium to fly on sustainable fuels. Another opportunity to cover part of the price premium emerged within the European Union’s Renewable Energy Directive (RED). The voluntary inclusion of SAF in the RED obligation is a mechanism implemented into legislation in The Netherlands since 2013. From 2016 onwards it will be possible for other member states to facilitate this as well, due to a change in the RED and Fuel Quality Directive (FQD) under the recent ILUC amendment: "In the case of suppliers of biofuels in aviation, Member States may permit such suppliers to choose to become contributors to the reduction obligation provided that those biofuels comply with the sustainability criteria" – Directive 2015/153 amending FQD (98/70/EC) and the RED (2009/28/EC). As all member states have implemented the RED differently, not all member states will have the same opportunities of implementing the voluntary aviation opt-in. Therefore, this report


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aims to give a structured insight in which EU member states can include the RED aviation opt-in. First, the Dutch system is explained. Second, the 28 EU member states are categorized on their potential of implementing the voluntary aviation opt-in. This results in six high potential member states which are analysed in-depth. For these 6 member states an overview of the current system, the relevant stakeholders and a guideline on how the voluntary aviation opt-in could be implemented into the RED legislation. The final part concludes and reflect upon the RED aviation opt-in, this includes a brief discussion on the post 2020 legislation.

1.2. Dutch Blueprint The Netherlands included the aviation opt-in as part of their RED legislation in 2013. As this was, by the time, not yet included in the RED directives, it caused some controversy within the EU and EC. After the EC accepted the aviation opt-in, it was included in the ILUC amendment in 2015, which enabled other member states to use the same opt-in. This section first explains the Dutch RED legislation including the aviation opt-in. This is followed by a supply-chain example, to show how it could be implemented in practice.

RED legislation including the aviation opt-in in the Netherlands The Netherlands has obligated suppliers of road transport fuels, under the Renewable Energy Directive, to supply a certain percentage of their fuels from renewable sources. This obligation is checked with biofuel certificates by the Dutch Emission Authority (NEA). The biofuel certificates in the Netherlands are called: Hernieuwbare Energieeenheden (HBEs). Each year, all the obligated parties have to show that they comply to the obligation by showing the right amount of HBEs. The parties have two options to obtain the HBEs:

- Produce biofuels themselves and therewith generate HBEs - Buy HBEs from a party having a surplus of HBEs

This system of HBEs enable the voluntary aviation opt-in. As in the Netherlands producers of Sustainable Aviation Fuels (SAF), can generate HBEs when supplying SAF to the Dutch market. As there is no obligation for the aviation sector, these HBEs can be sold to the obligated parties of the road transport obligation. With this money, the price premium between conventional jet fuels and SAF can partly be bridged.

Supply-chain implications In principal, the regulatory framework for the aviation opt-in is the same as for the road transport sector. This enables that the certificates can be sold to the road transport obligated parties. SkyNRG created in cooperation with the NEA a blueprint of how the registration process would work in a SAF supply-chain, this is shown in Figure 1. HBEs are generated by the aviation fuel supplier who hands over the proof of sustainability documents to the NEA. In return the HBE registrant, receives HBEs. As the aviation sector is not obligated under the RED, the registrant does not need the HBEs for its own obligation, and can therefore sell them to an obligated party of the road transport sector (the only monetary flow in this simplified diagram), who in turn fulfils its obligation by handing over the HBEs back to the NEA. For a more detailed explanation on the Dutch system and the considerations for this example, please refer to the full blue print in this report.


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Figure 1. HBE generation and sales in SAF supply-chain in The Netherlands

1.3. EU Member state categorization In this section, the 28 EU member states are categorised, based on their potential to implement the voluntary aviation opt-in into their RED legislation. First the criteria used to rate the countries are discussed. After which the results of the categorization are presented, ranking the member states in four categories from high to low potential.

Criteria The following criteria are used to systematically analyse the potential of the member states.

- Certificate system As the Dutch blueprint shows, an existing certificate system is crucial for a quick and easy implementation of the voluntary aviation opt-in. This criterion is therefore the key in the analysis.

- Other policy incentives Other incentives are also taken into account, as for example an existing tax exempt on road biofuels could be used to cover part of the SAF premium. Another example of a policy

BIO-REFINERY

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incentive that could be useful is an existing certificate system for the sustainable generation of power. This certificate system could potentially include SAF, however this is more difficult than including SAF directly in an existing certificate system specifically designed for biofuels.

- Local sustainable aviation fuel development opportunity The final criterion addresses the local fuel development opportunities and therefore is a combination of a number of criteria; Current local production, Domestic Jet fuel demand, Local airline sustainability score and Support from a local governmental organisation (e.g. the Department of Defence).

Categorization After analysing the criteria for each member states, four categories can be distinguished. Table 1. Categorization of EU member states

1. The first category consists of the member states in which the aviation opt-in is already

included in the legislation. This only holds for the Netherlands. No HBE registrant has currently used the aviation opt-in option in the Dutch legislation yet, however, SkyNRG has made the blueprint of how it could work and is working on proving this system by physically pushing SAF through the entire process.

2. The second category entails member states that have a tradable certificate system in place for road biofuels. It is important to note that it must be possible to trade these certificates independently from the physical biofuel, as the idea of covering the price premium will not work if the certificates generated by producing SAF cannot be sold to obligated parties in the road transport industry.

3. The third category, includes member states with a mix of policies. Certificate systems for power generation or without tradable possibilities are included in this category. Also countries with a very large potential due to large local demand, an existing second generation biofuel company or an alternative policy to financially stimulate biofuels are taken into account.

Category 1 Category 2 Category 3 Category 4

The Netherlands Germany Belgium Austria

Ireland Croatia Bulgaria

Italy Denmark Cyprus Portugal Finland Czech Republic Spain France Estonia United Kingdom Sweden Greece Hungary Latvia Lithuania Luxembourg Malta Poland Romania Slovakia Slovenia


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4. The fourth and final category includes all member states without any specific biofuel policy and with low scores on the other criteria. This is the category furthest away from an aviation opt-in in the near future.

Figure 2. Overview of member state potential to include the aviation opt-in

Conclusion The six member states in category two, have the biggest opportunity to implement the aviation opt-in into their existing RED legislation. Therefore, these member states are taken for further analysis. It is important to note, that this does not mean that the member states in category three and four will have no opportunity to implement SAF, however the current opportunity to easily implement the RED aviation opt-in is low and therefore these member states are not further analysed in this report.


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1.4. Member state analysis The six high potential countries from the categorization are analysed more in-depth to see how the aviation opt-in could be implemented. For these six countries an overview of the current RED legislation is provided. This includes the ILUC transposition timeline, this timeline indicates when the member state is open for public consultation, which is the window of opportunity to simultaneously implement the aviation opt-in. A first insight in how the aviation opt-in could practically work is also provided for each of the six member states. For further details, regarding stakeholders and the current RED system consult the member stat analysis in section four of the report.

1.4.1. Spain RED implementation status

Spain has currently a renewable energy source share in the road transport sector of 0.5%. This means Spain is behind schedule on reaching 10% in 2020. From January 2016 onwards, legislation changed to a general obligation for biofuels. Previously Individual obligations for biofuels in petrol and diesel existed. Public consultation for the ILUC implementation will take place in the summer of 2016.

Certificate system and potential aviation opt-in The Spanish certificate system is administrated and controlled by the Comisión Nacional de los Mercados y la Competencia (CNMC). Certificates are provided per tonne of oil equivalent. Figure 3, shows an overview of how the certificate system works, both the current road transport certification flow as well as the potential SAF certification flows The certificate registrant needs to show the proof of sustainability of the biofuel, gathered from the supply-chain (flow 1). The CNMC issues the certificates to the biofuel supplier (flow 2). If this system would include an aviation opt-in, the jet fuel supplier gets a certificate from CNMC, which can then be sold to the obligated party (flow 3).

ILUC Implementation timeline Public consultation period Final legislation Implementation Summer 2016 06-04-2017 01-09-2017


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Figure 3. Schematic representation of the Spanish RED aviation opt-in.

Spanish biofuel certificate system including the RED opt-in

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1.4.2. Portugal RED implementation status

In 2014, Portugal was on a 3.4% share of renewable energy sources in the transport sector. Still behind on the targets for reaching the 10% share in 2020. The Ministry of Environment and Ministry of Agriculture, Forestry and Rural Development, the ENMC and DGEG are working together on the renewed ILUC implementation, this is open for input from the industry in the summer of 2016. Legislation will be implemented in 2017.

Certificate system and potential aviation opt-in The obligation is controlled with a biofuel certificate system. The certificates “Titulo de Biocombustivels” (TdBs) are provided for each tonne of oil equivalent of biofuels put on the market. The obligated parties are “all entities that incorporate fuels on the market for end consumption for the road transport sector”. The Entidade Nacional Para O Mercado de Combustiveis (ENMC) issues the TdBs to the party that refines the biofuel, this could either be the SAF refinery or the road fuel refinery, see Figure 4. When SAF is refined, and sustainability is proven (flow 1), the tickets issued by the ENMC (flow 2) can then be sold to the obligated party in the road transport sector (flow 4).

Figure 4. Schematic representation of the Portuguese RED aviation opt-in.

Portuguese biofuel certificate system including the RED opt-in

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1.4.3. Ireland RED implementation status

Ireland is with its 5.2% renewable energy source share, slightly behind their RED implementation schedule. The National Oil Reserves Agency (NORA) is the organisation responsible for managing the biofuels obligation. Currently there is no indication that Ireland is working on the ILUC implementation and the only public consultation period that is announced, is ‘planned for 2016’.

Certificate system and potential aviation opt-in The Irish certificate system is call the Biofuel Obligation Scheme (BOS). The parties obligated under this system are: “all oil companies and oil consumer liable to pay the NORA Levy”. In other words: the party that puts the petroleum fuel on the market. The Irish system is closest to the Dutch system where registrants of certificates can be either the refinery of the fuel supplier. Therefore, the potential inclusion of the aviation opt-in can be constructed in multiple ways, a possible option is shown in Figure 5, where the certificate registrant gathers sustainability documents of the supply chain (flow 1). And NORA issues the certificate to the registrant (flow 2). This certificate can eventually be sold to the obligated party in the road transport sector (flow 3).

Figure 5. Schematic representation of the Irish RED aviation opt-in

Irish biofuel certificate system including the RED opt-in

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ILUC Implementation timeline Public consultation period Final legislation Implementation ‘Planned for 2016’ Unclear 2017


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1.4.4. Italy RED implementation status

Italy transposed RED Directive by means of the Legislative Decree no. 28/2011, according to which renewables are expected to cover at least 10% of final energy consumption in transport by 2020, and has currently reached 4.5%. The GSE (Gestore Servizi Eneregetici) accredited by the Ministry for Economic Development manages the biofuel development and are in their role responsible for the ILUC implementation. A public consultation in which the aviation opt-in could be suggested, takes place in June – July. As Italy was the first to mandate the use of advanced biofuels in the EU, their interest in new decarbonisation opportunities is large.

Certificate system and potential aviation opt-in The GSE (Gestore Servizi Eneregetici) accredited by the Ministry for Economic Development issues the certificates (called “CIC”, Certificates of Immission into Consumption) on an annual basis and periodic audits are carried out by the single certification body, ACCREDIA. Each certificate verifies that 10 GCal of biofuels have been made available for consumption. The obligated parties are: “The parties who sell gasoline and diesel to be used in road transport.” The certificates are tradable through bilateral negotiations. The aviation opt-in is similar to the Spanish situation, as the certificates are issued to the fuel supplier (Figure 6). The fuel supplier hands over the proof of sustainability, together with an independent audit, to the GSE (flow 1). After checking sustainability, the GSE issues the certificates (flow 2). The jet fuel supplier does not need the certificates and can therefore sell them to the obligated party in the road transport sector (flow 3).

Figure 6. Schematic representation of the Italian aviation opt-in

Italian biofuel certificate system including the RED opt-in

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ILUC Implementation timeline Public consultation period Expected Implementation June-July 2016 December 2016


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1.4.5. UK RED Implementation Status

The Renewable Transport Fuel Obligation (RTFO) scheme was introduced in 2008 and amended in 2015 to transpose the transport provisions of the RED into UK legislation. The current obligation level is 4.75%. The Department for Transport is responsible for the RED-ILUC implementation. Aviation biofuels currently can not take part in the UK system. The UK government established a Transport Energy Task Force last year that looked at future policy options for transport fuels and intends to conduct a formal public consultation on future RTFO legislation this summer, which will probably include including the aviation opt-in and addressing the issue of ILUC.

Certificate system and potential aviation opt-in The RTFO operates with tradable certificates called Renewable Transport Fuel Certificates (RTFCs) that are awarded to suppliers of sustainable biofuel. Obligated parties are: “those who supply more than 450,000 litres per year of road transport and non-road mobile machinery fuel.” These parties have to show they meet the obligation by handing over RTFCs. RTFCs may be bought or sold on the open market and have a maximum buy-out price of 30p/litre. In Figure 7, an overview of the certificate system in the road transport sector and a possible inclusion of the aviation opt-in is shown. The fuel supplier provides proof of sustainability which must be independently verified (flow 1). The RTFO issues the certificates to the fuel suppliers (flow 2). In a possible aviation opt-in the jet fuel supplier can sell the certificates to the road fuel supplier (flow 3).

Figure 7. Schematic representation of the United Kingdom’s aviation opt-in system

UK biofuel certificate system including the RED aviation opt-in

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1.4.6. Germany – In progress RED Implementation Status

Germany transposed RED Directive by means of both the Biomass Electricity Sustainability Ordinance of 23.7.2009 (BioSt-NachV) and the Biofuel Sustainability Ordinance of 30.9.2009. As the competent authority, the Federal Office for Agriculture and Food (BLE) publishes an annual evaluation and progress report. Currently Germany reached 6,6 %, which is on track to reach the 10% in 2020. This system has been changed in 2015 into the Greenhouse Gas (GHG) quota, in which Germany strives for 6% greenhouse gas reduction in 2020. This complies with the RED legislation and represents a different approach of ‘counting’ emission reduction levels. This means obligated companies in the oil industry have to place a minimum share of petrol- and diesel-replacing biofuels on the market. Fuel suppliers must now reduce the GHG emission of their fuels by 3% from 2015, 4.5% from 2017 and 7% from 2020. As the competent authority, the Federal Office for Agriculture and Food (BLE) publishes an annual evaluation and progress report. There is no current ILUC implementation guideline known in Germany.

Certificate system and potential aviation opt-in Obligated parties can fulfil their quota obligation either by entering biofuels into the fuel system of the road transport system directly or by contractually transfer the fulfilment of their obligation (but not the obligation itself) to another company. This is not the same as a certificate system as is used in e.g. the Netherlands. However, it does allow for third parties to introduce biofuels on the market and therewith fulfil someone’s obligation, which is worth the same as a certificate trading system.

1.5. Reflection The purpose of this report was to show the current state of the RED implementation and provide insights in how the aviation opt-in could work in EU member states. Six high potential member states were discovered where a relatively quick and short-term implementation of the aviation opt-in could take place. The practical implications might be time consuming, however the member states can use the Dutch blueprint as a guideline to accelerate implementation. It should be noted that these six member states are especially in the current timeframe high potential. It could very well be that on the longer term, other member states with e.g. a very strong home demand market be much more interesting to incentivise SAF. This report is therefore, for practical use, especially interesting for member states working on their ILUC amendments in 2016. The uncertainty around the post 2020 phase influences the current ILUC implementation, and therewith the aviation opt-in. This short-term security was the reason to focus on the member states that already have a certificate system in place. Although implementation might be difficult in this short time-frame, the aviation industry should push and pursue a wider implementation of the RED opt-in, to be ‘in the mind’ of legislators when creating post 2020 legislation. Furthermore, SkyNRG received indications that the European Commission is working towards a target for renewable energy in the aviation sector in the post 2020 legislation. The RED aviation opt-in, as shown in this report, could be a first start to prepare the local EU member state legislators for a wider scale implementation of sustainable aviation fuels in Europe.

SkyNRG 2016 (Document by: Renco Beunis and Eline Schapers)

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2. Dutch Blueprint 2.1. Introduction

2.1.1. Background As a result of the Renewable Energy Directive (RED), suppliers of fuels to the road transport market (gasoline, diesel or biofuels) are obliged to supply a certain percentage of these fuels from renewable sources. In order to show compliance with the renewable targets, these suppliers have to register their supplied fuels at the national authorities; they are ‘mandatory participants’. In the Netherlands, compliance checking is arranged via tradable HBEs (translated from Dutch: Renewable Energy Units – formerly known as bio-tickets). For every gigajoule renewable fuel supplied to the Dutch market they receive one HBE. Suppliers of fuels to the Dutch road transport market have to meet their annual target amount of HBEs, set by the Dutch Emission Authority (DEA) depending on their annual fuel supply to the Dutch road transport market and that year’s renewables percentage. Mandatory participants can either meet their annual HBE target by supplying self-produced or (inter)nationally procured renewable fuel, or by buying HBEs from other participants. Fuel suppliers supplying only biofuels have no annual HBE target. These suppliers can however voluntarily participate in the system by registering their supplied biofuels, thereby receiving HBEs. These they can sell to the mandatory participants in the road transport market.

2.1.2. EU RED opt-in for aviation biofuels SkyNRG among others, has put effort in making aviation biofuels eligible under the Dutch renewable energy targets. This was put into force in the national regulations in 2013 and since then suppliers of aviation biofuels to the Dutch transport market can generate and subsequently trade HBEs (sell to mandatory participants). The voluntary RED opt-in for aviation biofuels introduces a significant benefit for our market, as the generated and sold HBEs enable to lower the market price for aviation biofuels and as such help to further develop this market. The regulatory framework for RED-opt in for aviation biofuels is the same as in the road transport. The practical implementation of the HBE generation and sales has been developed over the last year by SkyNRG together with the DEA. This report provides background on the regulatory framework and aviation biofuel supply chain that formed the basis for defining a practical structure for HBE generation and sales. It describes the considerations made to come up with a workable structure and subsequently provides a guideline for HBE generation and sales. Although it is based on the Dutch situation, we hope it can offer support and relevant insights for other EU countries considering voluntary RED opt-in for aviation biofuels.


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2.2. Aviation biofuel supply chain and regulatory framework for RED opt-in

Since 2013, aviation biofuels are eligible under the Dutch renewable energy targets and HBEs can be generated and sold upon supply of aviation biofuels to the Dutch market. To be eligible under the renewable energy targets, both the biofuel in itself and the registrant (the party that is registering the biofuel with the authorities and thereby generating HBEs) need to meet the requirements set in the regulatory framework. This regulatory framework is the same framework as in the road transport market. Over the last year, the practical implementation of the HBE generation and sales has been developed, based on this regulatory framework and the aviation biofuel supply chain. This has been done in consultation with the Dutch Emission Authority and has led to a set-up where the aviation biofuel supplier to the market (SkyNRG) is the registrant and generates the HBEs. Before describing the considerations made that has led to this set-up, in this chapter we first provide an overview of the Dutch aviation biofuel supply chain and the regulatory framework.

2.2.1. Aviation biofuel supply chain The market for aviation biofuels is still relatively new; there is a limited number of producers worldwide and the supply chains used are not yet standardized. The most straightforward supply chain from feedstock to flight can though be described as follows:

1. Production: Bio-refinery produces aviation biofuel from sustainable feedstock.

2. Delivery to aviation biofuel supplier: Aviation biofuel supplier purchases this aviation

biofuel and gets it delivered at a blending/storage terminal that the aviation biofuel

supplier has contracted.

3. Blending & storage at pre-airport storage: Aviation biofuel supplier has the aviation

biofuel blended with fossil jet fuel (technical requirement). The blend is certified to the

relevant jet fuel quality specs (ASTM D1655/Def-Stan 91-91). The blend is stored at the

pre-airport storage terminal until further downstream distribution.

4. Delivery to airport: Although so far the majority of aviation biofuel has been delivered

to airports by trucks, pipeline transport to the airport, via existing systems, is expected

to become the standard way to get aviation biofuel delivered at the airport. Either

dedicated airport delivery pipeline systems can be used (e.g. ASP in The Netherlands)

or multi-destination pipeline networks like the Central European Pipeline System

(CEPS), of which approval for use of biofuels is on its way. At the airport the aviation

biofuel blend is received into the (commingled) airport storage system, owned by the

airport fuel consortium (usually a consortium of jet fuel suppliers and a major airline,

like AFS at Schiphol airport).


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5. Sales to airline: Aviation biofuel supplier sells the aviation biofuel blend to one of the suppliers in the airport fuel consortium and this supplier sells the fuel to the airline upon fueling the airline’s aircrafts (in some cases, the airline itself is part of this consortium, e.g. KLM at Schiphol).

2.2.2. Regulatory framework The requirements the biofuel and the registrant need to meet are stated in the national law; in The Netherlands this is recorded in the Environmental Management Act (Title 9.7 Renewable Energy for Transport). The regulatory framework can be summarized as follows:

1. The registrant:

a. is a Dutch enterprise;

b. holds title of the biofuel at a location certified for that type of biofuel;

c. is certified by an EU RED approved sustainability scheme (i.e. ISCC, RSB, etc.);

d. holds a permit for an Excise Goods Place for mineral oils, is a Registered

Consignee, or an Importer.

2. The registered biofuel:

a. is certified by an EU RED approved sustainability scheme;

b. is supplied to the next consignee without Proof of Sustainability (PoS). A PoS is

an official document stating the sustainability characteristics of the biofuel

(GHG intensity, feedstock used, etc.) as valid under the used sustainability

scheme. The PoS is addressed to the Dutch Emission Authority, and as a result

the biofuel loses its sustainability status and is supplied as regular fuel;

c. has to be supplied from a location in The Netherlands to the Dutch transport

market (supply to end-user by fulfilling excise duty, or supply to another Dutch

Excise Goods Place permit holder including title transfer);

d. should be supplied from a location that is certified by an EU RED approved

sustainability scheme and of which the registrant manages the mass balance.

This in practice means that this supply location should be included on the

sustainability certificate of the registrant.

Biofuels can either be registered for HBE generation or for tax reduction under EU ETS, not for both. Requirement 2.b prevents this from happening as on paper the biofuels lose their sustainability status upon registration for HBE generation. The end-user can therefore not claim the use of certified sustainable biofuels, hence under EU ETS the consumed biofuels are considered regular fossil fuel. The DEA is responsible for checking compliance to this regulatory framework; its inspectors perform audits at each mandatory and voluntary party. More details can be found on:

www.emissionsauthority.nl

www.government.nl/topics/environment/contents/biofuels

ec.europa.eu/energy/en/topics/renewable-energy/biofuels

http://www.emissionsauthority.nl/

http://www.government.nl/topics/environment/contents/biofuels

https://ec.europa.eu/energy/en/topics/renewable-energy/biofuels


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2.3. From legislation to implementation With the Netherlands being the first country to adopt eligibility of alternative aviation fuels under the national renewable energy targets, it also was the first to come up with a practical implementation of executing this eligibility. As the aviation biofuels industry still has to mature compared to the road transport biofuels industry and the aviation biofuel supply chain and roles within are not necessarily identical to that in the road transport biofuels market, while the directive and regulatory framework for HBE generation was primarily designed for the road transport industry only, this practical implementation wasn’t that straightforward. Various considerations have been made with respect to when, where and by whom in the Dutch aviation biofuel supply chain HBEs should be generated and sold, taking into account current and future supply chain setups (e.g. segregated vs non-segregated supply to airport) and the roles of the different supply chain partners. Different scenarios have been developed and evaluated by SkyNRG together with the DEA and the other partners in the supply chain. The starting point here has been that the selected structure/scenario should work in different supply chain set-ups. We provide the considerations made below.

2.3.1. Who and where to register and generate HBEs - Evaluated scenarios There are basically four actors in the supply chain that take title of the aviation biofuel and were therefore considered potential aviation biofuel registrants (= can generate and sell HBEs):

1. Airport fuel supplier (in airport fuel consortium)

2. Airline

3. Bio-refinery

4. Aviation biofuel supplier

Airport fuel supplier (in airport fuel consortium) as registrant

The fuel suppliers in the airport fuel consortium hold title of their fuel they store at the airport and subsequently deliver to aircrafts. In principle they could be the registrant and register upon delivery from the airport storage to aircrafts (they own the fuel and they have an Excise Goods Place permit – requirements for being the registrant). However, this would require the airport storage location to be EU RED certified. In addition, there is an issue with verifying the physical aviation biofuel delivery by this fuel supplier in the airport fuel consortium if the aviation biofuel has been delivered via a branched pipeline network system (the mode of transport we foresee as becoming the standard in the future). The policymakers request a proof of the physical delivery by the registrant while the book and claim way of delivery that is inherent to delivery via a pipeline network system makes this impossible: Pipeline network systems like CEPS operate by the banking system principle (everywhere in = everywhere out) rather than by physical point-to-point deliveries. As such, when supplying biofuel through a pipeline network system, delivery of aviation biofuel at the airport is demonstrated on an administrative basis. Physical delivery cannot be guaranteed since in fact the biofuel molecules can theoretically end up at all other outputs of the pipeline network system. Nor can the physical delivery of aviation biofuel be proven as it is a drop-in fuel and chemically indistinguishable from regular fossil jet fuel. For the policymakers, the physical delivery of the biofuel to the next administrative consignee within the country needs to be verified; just assuming that the aviation biofuel is fed into the system at one location in The


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Netherlands and by mass balancing delivered to the administrative consignee in The Netherlands is not sufficient. For the DEA the disability to provide physical evidence in case of delivery via a multi-destination pipeline system in practice means that any actor after the pre-airport storage location is unable to claim there has been a supply of certified sustainable aviation biofuel and hence can be the registrant.

NB. The airport fuel consortium itself could never be considered as the registrant, as the airport fuel consortium as an entity does not take title of the stored jet fuel.

Airline as registrant

As an end-user of jet fuel, airlines have to register their fuel consumption under EU ETS. Given that biofuels can either be used for HBE generation or tax reduction under EU ETS, and both incentives vary in magnitude, it could be beneficial for an airline to have the flexibility to choose between both. Being the registrant for HBE generation, all requirements for claiming the use of aviation biofuels under EU ETS are also met (procurement with PoS). Basically an airline could only be the registrant if it is a shareholder in the airport fuel consortium (owning the airport storage and distribution system). Only in that case, it supplies as owner of the fuel from the airport storage into the Dutch aviation market (supply for its own use or supply to another airline) and can have an Excise Goods Place permit (both requirements for being the registrant). However, most airlines are not part of the airport fuel consortium and if they are, this generally only is the case at their ‘hub airports’. For example, in The Netherlands it would only be KLM that could be the registrant on this basis. And obviously only if they would have their relevant operations certified under an EU RED approved sustainability scheme; although this is not impossible it might be considered a hassle for an airline to do this. In addition, the same limitation as described in above paragraph holds here as well; if the aviation biofuel is supplied to the airport via a multi-destination pipeline system, no evidence of the physical delivery can be provided.


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Bio-refinery as registrant

In theory, the bio-refinery (if located in the country the RED opt-in for aviation biofuels is eligible) itself can be the aviation biofuels registrant and would register when it sells the biofuels from its refinery to the Dutch transport market. In practice however, the bio-refinery is likely to be located outside the country the RED opt-in is applicable in as there are not yet many bio-refineries producing aviation biofuels. For example, in The Netherlands there would only be one which might not automatically be the most favourable option; importing aviation biofuels could be more economical. For other countries considering the aviation RED opt-in importing might be required as well, having no bio-refineries yet producing aviation biofuels. Furthermore, many bio-refineries have no blending facilities. Selling unblended aviation biofuels without Proof of Sustainability might be a challenge and registering unblended biofuels is not per se possible (in The Netherlands it is).


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Aviation biofuel supplier as registrant

The aviation biofuel supplier, described before as the party that sources the neat aviation biofuel, blends it and sells it from a pre-airport storage terminal into the Dutch aviation market (either directly to an airline or to a fuel supplier in the airport fuel consortium). The aviation biofuel supplier holds title of the fuel up to the moment of delivery from the pre-airport storage terminal and has an (fictive) Excise Goods Place permit on the pre-airport storage terminal where it (blends and) stores the fuel. On that basis the aviation biofuel supplier could be the registrant. Since the requirement of providing evidence of the physical supply of the aviation biofuel holds only up to the point of registration – supplying from the pre-airport storage terminal – no further requirements are set on the transport to the airport. Hence this setup works for any mode of transport, e.g. pipeline network systems, rail cars, tanker trucks, etc. NB: As a pipeline system is an Excise Goods Place itself, the physical supply of aviation biofuel is actually not directly to the administrative consignee (the supplier in the airport fuel consortium, holding an Excise Goods Place permit and taking title of the aviation biofuel), but to the pipeline system’s Excise Goods Place. In discussing the set-up of the aviation biofuel supply chain in The Netherlands, the DEA confirmed that the pipeline sytem is seen as a transporter of the biofuels only. Hence, the pipeline operator taking title of the supplied biofuel is not required in order for the aviation biofuel supplier to be the registrant (requirement 2.c from the regulatory framework).


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2.3.2. Conclusion The investigation and evaluation of the different scenarios with the DEA has led to the conclusion that, although any party could in specific situations be the aviation biofuels registrant, no matter what the supply chain set-up is and no matter who the final end-user is, registration by the aviation biofuel supplier at point of supply from the pre-airport storage can always be done in accordance with the regulatory framework.


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2.4. HBE generation and sales guideline – a blueprint In the Netherlands, in the practical set-up of the voluntary RED opt-in, the aviation biofuel supplier is registering the biofuels at the Dutch Emission Authority upon supply to the Dutch aviation market, generating HBEs by doing so and selling these HBEs to the Dutch road transport market. Below we provide a guideline of how this process works in practice and how the requirements set by the regulatory framework are met throughout the supply chain.

0. The aviation biofuel supplier is the registrant and therefore has to comply to the set of

requirements of the regulatory framework.

The registrant is a Dutch enterprise.


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The registrant is certified by an EU RED approved sustainability scheme (i.e. ISCC, RSB,

etc.). The certificate should cover the aviation biofuels operations (e.g. blending and

storage) and the type of biofuel that will be supplied.

The registrant holds title of the aviation biofuel at the moment of supply to the Dutch

aviation market (in practice, at the moment it supplies from pre-airport storage

location into transport system to one of the airport fuel consortium’s suppliers). This

is because the registrant may only register its own biofuels that they supply to the

Dutch transport market and not those from other parties. Hence only biofuels

recorded in the mass balance of the registrant can be registered.

The location from where registrant supplies to the Dutch aviation market (the pre-

airport storage location) needs to be part of the registrant’s sustainability certificate.

This is to ensure that the entire supply chain up to the point of supply is certified

(required for claiming a supply of certified biofuel) and to ensure the (relevant part of

the) terminal’s mass balance is linked to the registrant and as such can be verified by

independent auditors.

The registrant holds an Excise Goods Place permit on the location from which is

supplied (the pre-airport storage location). In case the contracted location already has

such a permit, the registrant may obtain a fictional Excise Goods Place permit that will

be coupled to the location’s original permit. In case the aviation biofuel is procured

internationally, an Importer permit is needed instead.

The registrant holds an HBE account (at the DEA) that allows for registering biofuel

supplies.

1. The aviation biofuel supplier purchases biofuel from a bio-refinery with a PoS.

The purchase should be accompanied with a Proof of Sustainability (PoS). This PoS

demonstrates that the feedstock used for production and the fuel produced by the

bio-refinery complies with the EU RED sustainability requirements.

The PoS contains information on the GHG intensity of the aviation biofuel, the

supplier’s sustainability certificate, type of feedstock used, etc.

2. Aviation biofuel supplier blends and stores at pre-airport storage location.

The pre-airport storage location is the location from where the aviation biofuel is

supplied to the Dutch aviation market. The registrant needs to control the biomaterials

mass balance of this location, hence this location needs to be included on the

registrant’s sustainability certificate.

If blending and pre-airport storage take place in different locations, only the pre-

airport storage location (being the location from where the biofuel is supplied to the

Dutch aviation market) needs to be included on the registrant’s sustainability

certificate. However, the blending location itself should be certified as well to not

disrupt the certified supply chain.


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3. Aviation biofuel supplier supplies to Dutch aviation market.

Registering a supply of biofuel to the Dutch transport market is possible either when

the registrant supplies to another Excise Goods Place permit holder including title

transfer (actual consumption of the biofuel is not required prior to registration), or

when supplied to end-users by fulfilling the excise duty. From the pre-airport storage

location, the aviation biofuel is supplied to the supplier in the airport fuel consortium;

an Excise Goods Place permit holder. Title transfers at the moment the aviation biofuel

leaves the storage location and enters the transport system, e.g. pipeline.

Upon supplying to the Dutch aviation market, the PoS of the aviation biofuel is

addressed to the DEA, not to the physical consignee. As a result, the supplied aviation

biofuel cannot again be claimed under EU RED, preventing double counting of the

same biofuel.

4. Aviation biofuel supplier registers biofuel supply at the DEA after supplied to Dutch aviation

market.

The supply of aviation biofuel can be registered at the registrant’s account at the DEA

directly after supplying to the Dutch aviation market.

Information on the aviation biofuel needs to be provided (e.g. GHG intensity, volume,

used feedstock and double counting eligibility, etc.) and should be accompanied by the

PoS.

Evidence of the physical supply is not needed at this stage, but will be needed during

audits. The registrant needs to have its registrations verified by an independent

auditor before the end of each year of compliance. The DEA checks this verification

report. Next to this, also the DEA’s inspectors perform audits at the registrant, which

can be throughout the year.

HBEs are granted directly upon registration and can be traded subsequently.

5. Aviation biofuel supplier sells HBEs to obligated parties in road transport market.

Directly after registering the supplied aviation biofuel, the (instantly granted) HBEs can

be sold.

HBEs have no expiry date, but only a certain percentage (after mandatory HBEs are

subtracted from the account at the end of each compliance year by the DEA) can be

saved for the next year. From the mandatory HBE target (road transport suppliers) 25%

can be saved, from the amount voluntarily registered (e.g. aviation biofuel suppliers)

10% can be saved.

There is no open and transparent system for HBE trading, hence trading of HBEs is

done bilaterally between parties on contractual basis. As a result, the value of an HBE

may not be harmonized system wide and depends on each contract.

Trading can be outsourced to brokers, having more information on the trade market

and also offering long term hedging (usually up to one year).


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2.5. Conclusion Suppliers of fuels to the road transport market are obliged to supply a certain percentage of these fuels from renewable sources as a result of the RED. Since 2013, a RED opt-in for aviation biofuels is applicable in the Netherlands; aviation biofuels are eligible under the Dutch renewable energy targets and HBEs can be generated and sold upon supply of aviation biofuels to the Dutch market. The regulatory framework for RED-opt in for aviation biofuels is the same as in the road transport. The practical implementation of the HBE generation and sales has been developed over the last year by SkyNRG together with the DEA and has led to a set-up where the aviation biofuel supplier is the registrant and seller of HBEs. Although any party could in specific situations be the aviation biofuels registrant, it was found that no matter what the supply chain set-up is and no matter who the final end-user is, registration by the aviation biofuel supplier at point of supply from the pre-airport storage can always be done in accordance with the regulatory framework. The considerations that have been made to come to this set-up as well as the practical guideline for aviation biofuel registration and HBE sales can offer relevant insight to other EU countries considering voluntary RED opt-in for aviation biofuels.


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3. EU Member State categorization This section provides the full analysis on the EU Member State (MS) categorization. With this categorization an insight is provided into the potential of each MS to include the voluntary RED opt-in for aviation biofuels in existing RED legislation on the short term. First the method is explained, stating the different criteria. Then, for each member state an overview is provided about these criteria. The section is finalised with a conclusion stating the four different categories.

3.1.1. Method The analysis is based on four criteria, in the following a brief explanation is provided on the criteria and the method of analysis. Every MS is assigned to a category after which analysing the criteria.3 Four categories can be distinguished, category 1 is the category in which the aviation opt-in is already present in legislation while category 4 is the category for MS with the least promising circumstances to implement the voluntary aviation opt-in into the existing legislation.

Policy a. Obligation

Every Member State (MS) is, under the Renewable Energy Directive4, obligated to have a 10% share of the total energy in the transport sector coming from Renewable Energy Sources (RES) by 2020. In this section it is determined how each MS is pursuing this goal and what the current (2014) share of RES in the transport sector is according to (Eurostat, 2014a) data.

b. Certificate System The MS can forward the obligation to stakeholders in the MS’ fuel sector in order to reach 10% in 2020. One of the methods to do this is by using ‘green certificates’. A stakeholder is, within such a system, obligated to have a certain amount of green certificates (based on the amount of fuel produced or traded within the MS). These certificates can generally be received by either producing biofuel and blending it into the conventional fuel supply, or by buying certificates from either a non-obligated party that produces biofuels or from another stakeholder who generated too many green certificates for their own obligation. This trading scheme is the most important criterion for this analysis as the aviation sector is not included in the 10% obligation as stated in RED. This means that, when producing SAF, the green certificates can be sold to an obligated party. This could cover part of the premium that exists between bio and conventional jet fuel.

c. Other Incentives Other clear biofuel incentives that might be an opportunity to cover the price premium are also included in the analyses. This criterion is also used as an indication for the MS’ activities on stimulating renewable technologies in general.

3 The analysis is primarily based on the National Action plans of each EU MS (European Commission, 2010) and the National progress reports on renewable energy goals (European Commission, 2013). 4 Renewable Energy Directive, 2009/28/EC; Directive 2015/1513, amending RED 2009/28/EC


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Local Production d. Advanced Biofuel Producers

Is there an advanced biofuel producer currently active, and what is the historical activity of the MS with producing biofuels.5

e. Feedstock Opportunity Score Based on a previous study of SkyNRG; the feedstock opportunity score is based on the following criteria: Agricultural productivity, Oilseed crop yield, Harvested oil seed, Arable land, Unused arable land, UCO potential. Every country receives a score from 0 – 1 from which a European average is calculated. In this report the feedstock opportunity score is indicated as above EU average, EU average or below EU average.

Fuel Demand f. Domestic Jet Fuel Demand

The domestic jet fuel demand is taken from Eurostat6 and based on the 2014 fuel levels. The fuel demand is indicated in metric tonnes / year, as this is the prevailing way of showing fuel use. As for the feedstock score, it is also indicated whether a country has a below EU average, EU average or above EU average fuel demand.

g. Main Local Airline Sustainability Score The Airline sustainability score is important as it can aggregate demand for bio jet fuel. The score is based on the main local airline in a specific Member State. And scores are indicated as follows:

0) No clear sustainability strategy +) Clear sustainability strategy with CO2 reduction and reporting (without SAF) ++) Clear sustainability strategy with CO2 reduction and reporting (including SAF) +++) Clear sustainability strategy with CO2 reduction and reporting (including SAF + already conducted SAF flights or involved in major SAF projects)

Support from specific governmental bodies This criterion includes possible governmental bodies that could help influence the biofuel policy making. The Deparment of Defence (DoD) is an example of a governmental body that could help with the acceleration of biofuels, as they have large incentives in creating a stable fuel supply line.

5 This is based on each EU Member States website on the European Biofuels Technology Platform; for example: http://biofuelstp.eu/country/austria.html 6 (Eurostat, 2014b)


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3.2. Austria - Category 4 1. Policy

Obligation Stimulation Austria has set obligations on importers and distributors of transport fuels to include biofuels in their fuel mix. Obligations build up to 10% in 2020, as prescribed by the RED. Austria does apply Article 21(2) from the RED, stating the contribution made by biofuels produced from wastes, residues, non-food cellulosic material, and lingo cellulosic material is considered to be twice that made by other biofuels. Companies are not allowed to distribute their fuels if the obligation criterion is not met. Austria is already very close to their 10% target with 8.9%, mainly due to electricity in transport and the blending of biodiesel. Certificate System No trading scheme or system of certificates exist in Austria. Other Incentives

- Investment subsidies exist for the purchase of electric vehicles. - Feed-In tariffs for electricity production from renewable sources exist.

2. Local Production

Advanced Biofuel Producers No advanced biofuel producers exist in Austria. Feedstock Opportunity Score Austria has a below average feedstock opportunity score.

3. Fuel Demand Domestic Fuel Demand Austria had, in 2014, a domestic fuel demand of: 663.000 metric tonnes/year. This is an EU average demand. Main airline sustainability goals Austrian airlines has a ++ performance on sustainability.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Austria.


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3.3. Belgium - Category 3 1. Policy

Obligation Stimulation Belgium has, in the transport sector, introduced an obligation system of biofuels and mad it mandatory for the fuel industry to include a proportion of biofuels in the fuel mix. Obligations build up to 10% in 2020, as prescribed by the RED. Belgium is currently with 4.9% slightly behind schedule on reaching the 10%. Certificate System A Renewable Energy Trading system exists for the production of electricity. Suppliers of electricity to consumers are obliged to have such certificates and thus need to produce or buy these. There is currently no certificate system for Biofuels in Belgium. Other Incentives

- Tax exemptions exist for biofuel producers, thus they don’t have to pay any taxes on the produced fuels.

- The government take an exemplary role on electrical vehicle use and supports this EV development with tax incentives for vehicles and charging stations.

2. Local Production

Advanced Biofuel Producers No advanced biofuel producers exist in Belgium. Feedstock Opportunity Score Belgium has a below average feedstock opportunity score.

3. Fuel Demand Domestic Fuel Demand Belgium had, in 2014, a domestic fuel demand of: 1.278.728 metric tonnes/year. This is an EU average demand. Main airline sustainability goals Brussels Airlines has a + performance on sustainability.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Belgium.


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3.4. Bulgaria - Category 4 1. Policy

Obligation Stimulation Bulgaria has set obligations on importers and distributors of transport fuels to include biofuels in their fuel mix. Obligations build up to 10% in 2020, as prescribed by the RED. No stimulating policy exists apart from the obligations. In 2014, Bulgary had a share of 5.3% from renewable sources in the transport sector. The State Agency for Metrology and Technical Surveillance is the monitoring organisation of the obligation. Certificate System No trading scheme or system of certificates exist in Bulgaria. Other Incentives

- There is a tax reduction for fuel producers and distributors for blended biofuel products, with at least 4 – 5% biofuel in the blend.

- There are some voluntary investment stimulation programs, for sustainable energy projects.

- Feed-In tariffs for electricity production from renewable sources exist.

2. Local Production Advanced Biofuel Producers No advanced biofuel producers exist in Bulgaria. Feedstock Opportunity Score Bulgaria has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Bulgaria had, in 2014, a domestic fuel demand of: 166.633 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals Bulgaria air has no ambition to meet certain sustainability criteria and thus scores 0.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Bulgaria.


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3.5. Croatia - Category 3 1. Policy

Obligation Stimulation Croatia has set obligations on importers and distributors of transport fuels to include biofuels in their fuel mix. Obligations build up to 10% in 2020, as prescribed by the RED. In 2014, Croatia was behind schedule on 2,1% from renewable sources in the transport sector. MINGO is responsible for the establishment and supervision of measures. HROTE is responsible for

the implementation of measures.

Certificate System No trading scheme or system of certificates exist in Croatia. Other Incentives

- There is a tax reduction for fuel producers and distributors for biofuels. - Biofuels are stimulated with a cash incentive. Biofuel producers get 0.22 €/L biodiesel

and 0,003 €/L bioethanol. Producers must have the status of an eligible producer and produce more than 1 TJ of biofuel annually, in order to receive this financial stimulation (AEBIOM, 2015).

2. Local Production

Advanced Biofuel Producers No advanced biofuel producers exist in Croatia. Feedstock Opportunity Score Croatia has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Croatia had, in 2014, a domestic fuel demand of: 127.247 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals Air Croatia has no ambition to meet certain sustainability criteria and thus scores 0.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Croatia.


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3.6. Cyprus - Category 4 1. Policy

Obligation Stimulation Cyprus has the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED, however there are no obligations set on the importers and/or distributors of transport fuels. In 2014, Cyprus was behind schedule with 2,7% from renewable sources in the transport sector. Certificate System No trading scheme or system of certificates exist in Cyprus. Other Incentives

- No other incentives exist to possibly stimulate biofuels.

2. Local Production Advanced Biofuel Producers No advanced biofuel producers exist in Cyprus. Feedstock Opportunity Score Cyprus has a high above score on feedstock opportunity, this is mainly due to their large amount of unused arable land and their favourable climate. In practice this might not be very useful for actual biofuel production.

3. Fuel Demand Domestic Fuel Demand Cyprus had, in 2014, a domestic fuel demand of: 243.940 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals The local airline went bankrupt and has thus no sustainability score.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Croatia.


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3.7. Czech Republic - Category 4 1. Policy

Obligation Stimulation Czech Republic has the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED, and has obligated the distributors of transport fuels to blend in percentages of biofuels into their fuel mix. In 2014, Czech Republic was on schedule with 6,1% from renewable sources in the transport sector. Certificate System No trading scheme or system of certificates exist in Czech Republic. Other Incentives

- There are tax incentives for the high percentage (e.g. E85) biofuels. - Feed-In tariffs exist to stimulate sustainable energy production

2. Local Production

Advanced Biofuel Producers No advanced biofuel producers exist in the Czech Republic. Feedstock Opportunity Score Czech Republic has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Czech Republic had, in 2014, a domestic fuel demand of: 294.174 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals Czech Airlines has no ambition to meet certain sustainability criteria and thus scores 0.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Czech Republic.


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3.8. Denmark- Category 3 1. Policy

Obligation Stimulation Denmark has the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED, and has obligated the market of distributors who trade diesel and petrol on the market. In 2014, Denmark was behind schedule with their 5,8% from renewable sources in the transport sector. Although Denmark has a very ambitious goal of a 40% RES share in total energy, biofuels aren’t stimulated specifically. However, in March 2016 the Danish government decides on a new obligation of specifically second generation biofuels to a 2.5% blend level (The Danish Government, 2013; European Biomass Industry Association, 2013). Certificate System No trading scheme or system of certificates exist in Denmark. Other Incentives

- There are tax incentives for electric vehicles - There is an exemption from CO2 tax for biofuels - There are R&D budgets for the development of biofuel facilities - Feed-In tariffs exist to stimulate sustainable energy production

2. Local Production

Advanced Biofuel Producers - Dong Energy is a large energy company and has some demonstration facilities. - Maabjerg Energy Centre, NER300 project (Maabjerg Energy Center, 2016).

Feedstock Opportunity Score Denmark has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Denmark had, in 2014, a domestic fuel demand of: 870.208 metric tonnes/year. This is an EU average demand. Main airline sustainability goals Scandinavian Airlines has an extensive sustainability program and thus scores +++.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Denmark.


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3.9. Estonia - Category 4 1. Policy

Obligation Stimulation Estonia has the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED. However, the market of distributors is not obligated. In 2014, Estonia is very far behind schedule with only 0,2% renewable sources in the transport sector. Certificate System No trading scheme or system of certificates exist in Estonia. Other Incentives

- Fuel excise duty does not hold for biofuels in Estonia

2. Local Production Advanced Biofuel Producers No advanced biofuel producers exist in Estonia. Feedstock Opportunity Score Estonia has a below average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Estonia had, in 2014, a domestic fuel demand of: 28.147 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals The main airline of Estonia is bankrupt and therefore has no sustainability score.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Estonia.


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3.10. Finland - Category 3 1. Policy

Obligation Stimulation Finland has set obligations on importers and distributors of transport fuels to include biofuels in their fuel mix. Obligations are set higher then the 10% in 2020, as prescribed by the RED. Currently Finland already reached 20.9%, which is the highest percentage of biofuels blended into the fuel mix of all EU Member States. Certificate System No trading scheme or system of certificates exist in Finland. Other Incentives

- A taxation mechanism exists to drive biofuel development into the direction of advanced biofuels, as fuels are taxed on the amount of life cycle CO2 emissions.

- A number of local investment programs to stimulate biomass and renewable electricity development.

2. Local Production

Advanced Biofuel Producers - UPM Biofuels, the world leading wood-based biodiesel producer is located in Finland

and is responsible for the sharp increase in renewable diesel in the country. Feedstock Opportunity Score Finland has a below average score on feedstock opportunity, however it should be noted that this feedstock opportunity does not take the large wood industry of Finland into account.

3. Fuel Demand Domestic Fuel Demand Finland had, in 2014, a domestic fuel demand of: 727.714 metric tonnes/year. This is an EU average demand. Main airline sustainability goals Finnair has an extensive program with high sustainability criteria and thus scores +++.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Finland.


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3.11. France - Category 3 1. Policy

Obligation Stimulation France has set obligations on importers and distributors of transport fuels to include biofuels in their fuel mix. Obligations are set to reach the 10% in 2020, as prescribed by the RED. Currently France reached 7.8 %, which is on track to reach the 10% in 2020. Certificate System No tradable certificate system exists in France. Other Incentives

- Biodiesel and bioethanol used for fuel purposes and blended within conventional fuels benefit from a partial exemption of the domestic consumption tax. Depending on the source of biofuels the tax exemptions are € 0,14/L for Ethanol and € 0,08 / L for Biodiesel. This rule only holds for fuels with at least a 7% biofuel component.

- An extensive feed-in tariffs system exists to stimulate sustainable electricity generation

- A number of local investment programs to stimulate biomass and renewable electricity development.

2. Local Production

Advanced Biofuel Producers - Total is investing in converting an oil refinery to process UCO and other waste streams

into biofuels. - BioTfuel is developing new facilities for the production of advanced biofuels as well.

Feedstock Opportunity Score France has an above average feedstock opportunity score.

3. Fuel Demand Domestic Fuel Demand France had, in 2014, a domestic fuel demand of: 6.752.221 metric tonnes/year. This is an above EU average demand. Main airline sustainability goals Air France – KLM has high ambitions to meet sustainability criteria and thus scores +++.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in France.


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3.12. Germany - Category 2 5. Policy

Obligation Stimulation Germany has set obligations on importers and distributors of transport fuels to include biofuels in their fuel mix. Obligations are set to reach the 10% in 2020, as prescribed by the RED. Currently Germany reached 6,6 %, which is on track to reach the 10% in 2020. This system is changed in 2015 into the Greenhouse Gas quota, in which Germany strives for 6% greenhouse gas reduction in 2020, this corresponds with RED legislation, but is a different approach of ‘counting’ emission reduction levels. Certificate System A transformation towards the greenhouse gas quotas has taken place in 2015. In this greenhouse gas quota system, trading between obligated and non-obligated parties is possible. This is a major possibility to include SAF as the system is very comparable to the Dutch situation (UFOP, 2014; Department for Transport, 2015) Germany has an extensive tradable certificate system for electricity production. As in Sweden, these ‘Guarantees of Origin’ are in place to stimulate green electricity production, however with some changes in regulation biofuels might be able to create such guarantees of origin and therewith compete on the market as well. Other Incentives

- Biofuels profit from reduced taxes on production. - Germany has an extensive legislative framework to stimulate electricity with the GO’s

and feed-in tariffs.

6. Local Production Advanced Biofuel Producers

- Many research facilities are working on the development of advanced biofuels, no large commercial facilities have been build yet.

Feedstock Opportunity Score Germany has an average feedstock opportunity score.

7. Fuel Demand Domestic Fuel Demand Germany had, in 2014, a domestic fuel demand of: 8.793.847 metric tonnes/year. This is an above EU average demand. Main airline sustainability goals Lufthansa has high ambitions to meet sustainability criteria and thus scores +++.

8. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Germany.


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3.13. Greece - Category 4 1. Policy

Obligation Stimulation Greece is working towards meeting the 2020 targets through the elaboration of specific policies and measures and the acceleration of the green economy through green development and enhanced competitiveness of the private sector. Biodiesel quantities are, in contrast to other EU MS, allocated through tenders towards producers or importers who are interested in participating in this quota system. So far this does not seem to work well, as Greece reached 1.4% out of the 10% target. Certificate System Greece has no certificate system in place to support the biofuel development. Other Incentives

- A Feed-In tariff exist to stimulate renewable electricity generation


- Elin Biofuels S.A. is a local producer of biofuels, that tries to stimulate advanced biofuels.

Feedstock Opportunity Score Greece has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Greece had, in 2014, a domestic fuel demand of: 966.572 metric tonnes/year. This is an EU average demand. Main airline sustainability goals Aegean Airline has committed to improve fuel consumption by 1.5% each year until 2020; to stabilize carbon dioxide emissions and achieve a net zero carbon footprint starting in 2020; to reduce carbon dioxide emission levels by 50% from 2005 until 2050. These are the standard sustainability goals and do not directly take biofuels into account and therefore a + score.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production biofuels in Greece.


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3.14. Hungary - Category 4 1. Policy

Obligation Stimulation In Hungary regulations for the use of biofuels have existed since 2005. In the first period, which lasted until 2009, they provided incentives for the use of biofuels through tax reliefs. In 2009 the tax relief on biofuels admixed to petrol and motor diesel oil was abolished, and was replaced by a marketing obligation (imposing heavy fines in the case of failure to fulfil this obligation). Hungary is on track of reaching the 10% target, as they currently are on a 6.9% share. Certificate System Hungary has no certificate system in place to support the biofuel development. Other Incentives


2. Local Production Advanced Biofuel Producers No advanced biofuel producers exist in Hungary. Feedstock Opportunity Score Hungary has a below average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Hungary had, in 2014, a domestic fuel demand of: 159.792 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals Wizz air, the local airline, has no sustainability goals and scores 0.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production biofuels in Hungary.


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3.15. Ireland - Category 2 1. Policy

Obligation Stimulation Ireland has set out a Biofuel Obligation Scheme (known as BOS in Ireland). Currently, Ireland reached 5.2% and they are working towards the 10% goal in 2020. Ireland also had a tax relief policy in place, however this ended in 2010. Certificate System Ireland is a country with a tradable certificate scheme which is in place to stimulate and force the local fuel importers and producers to put biofuels on the market. Important is that while the volume of levy paid biofuels placed on the market will dictate how many BOS certificates each party can apply for, it will be the number of BOS certificates held in each party's account at the end of the reconciliation period which will determine if the obligation is met, not the physical volume of biofuel placed on the market. BOS certificates can therefore also be transferred between BOS participants, independently of the biofuel. The price of certificates is a commercial matter between the buyer and seller. The organisation in place of administration and control of this system is the National Oil Reserves Agency (NORA).

Other Incentives - Ireland has the ambitious target of having 10% of all cars being electric Vehicles (EV)

in 2020. There is a grant scheme in place to stimulate this goal. - Ireland has a Renewable Energy Feed-In Tariff in place to stimulate the generation of

sustainable electricity.

2. Local Production Advanced Biofuel Producers No advanced biofuel producers exist in Ireland. Feedstock Opportunity Score Ireland has a below average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Ireland had, in 2014, a domestic fuel demand of: 633.109 metric tonnes/year. This is an EU average demand. Main airline sustainability goals Air Lingus has no sustainability goals and scores 0.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production biofuels in Ireland.


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3.16. Italy - Category 2 1. Policy

Obligation Stimulation Italy states: looking to the future, the intention is to take action mainly through the obligatory minimum quota, in line with sustainability criteria and taking into account second- and third-generation biofuel development, as well as the social sustainability of biofuels. Italy therefore put out an obligation stimulation and currently reached: 4.5%, a little behind schedule for the 10% goal in 2020. Certificate System “Certificates for making biofuels available for consumption” were established in order to monitor the fulfilment of this obligation. The certificates are issued on an annual basis by the Ministry for Agriculture, Food and Forestry (MIPAAF). One certificate verifies that 10 Gcal of biofuel have been made available for consumption in Italy. Article 21 biofuels are granted one certificate for every 5 Gcal of biofuels. The certificates are tradable, so it is possible for those liable for the obligation to make biofuel available to fulfil the legal obligation by buying certificates from other parties who have too many. The certificates are traded through bilateral negotiations and subsequent notification to the MIPAAF certification system.

Other Incentives - Italy has an extensive Feed-In Tariff system in place to stimulate the generation of

sustainable electricity. This replaced an obligation policy for electricity from 2012 onwards.

2. Local Production

Advanced Biofuel Producers - ENI, is producing biofuels with the Honeywell-UOP technology - Beta Renewable has a cellulosic ethanol plant at Crescentino

Feedstock Opportunity Score Italy has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Italy had, in 2014, a domestic fuel demand of: 3.708.840 metric tonnes/year. This is an above EU average demand. Main airline sustainability goals Alitalia has a program to reach sustainability goals and scores ++.

4. Support from governmental Bodies (e.g. DoD) ‘Flotta Verde’ is a military initiative in collaboration with the ‘Green Fleet’ initiative of the US Navy. This military body is putting effort in the development of biofuels for military purposes (Jim Lane, 2015)


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3.17. Latvia - Category 4 1. Policy

Obligation Stimulation Latvia has an obligation scheme in place to obligate the fuel importers and producers in the country to blend in a percentage of biofuels. However, Latvia currently has a share of 3.2% biofuels and thus is fairly behind schedule on reaching the 10% in 2020. Certificate System Latvia has no certificate trading scheme in place to stimulate biofuels. Other Incentives

- Latvia has a system in place for the reduction of excise duty, this applies for different types of biofuels.

2. Local Production

Advanced Biofuel Producers No advanced biofuel producers exist in Latvia. Feedstock Opportunity Score Latvia has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Latvia had, in 2014, a domestic fuel demand of: 120.992 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals Air Baltic, the local airline in latvia, has no sustainability goals and scores 0.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production biofuels in Latvia.


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3.18. Lithuania - Category 4 1. Policy

Obligation Stimulation Lithuania has the obligation of reaching 10% of RES shares in 2020. However, they have not obligated any party in specific to fulfil this apart from stating that ‘the state is responsible for the formation of appropriate conditions’. Although no party is obligated specifically, Lithuania currently has a share of 4.6% biofuels in their fuel mix. Certificate System Lithuania has no certificate trading scheme in place to stimulate biofuels. Other Incentives

- Lithuania has some incentives in place for the generation of renewable electricity, policies on biofuels are very limited.

2. Local Production

Advanced Biofuel Producers No advanced biofuel producers exist in Lithuania. Feedstock Opportunity Score Lithuania has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Lithuania had, in 2014, a domestic fuel demand of: 74.570 metric tonnes/year. This is an EU average demand. Main airline sustainability goals The local airline in Lithuania is bankrupt and thus scores 0.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production biofuels in Lithuania.


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3.19. Luxembourg - Category 4

1. Policy Obligation Stimulation Luxembourg has obligated fuel importers to mix biofuels into their fuel blend, this has currently resulted in a share of 5.2% biofuels in their fuel mix. Certificate System luxembourg has no certificate trading scheme in place to stimulate biofuels. Other Incentives

- Luxembourg has Feed-In Tariffs in place to stimulate electricity generation. - Also investments are available to stimulate smart networks as well as the

infrastructure to support charging of electrical vehicles

2. Local Production Advanced Biofuel Producers No advanced biofuel producers exist in Luxembourg. Feedstock Opportunity Score Luxembourg has a below average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Luxembourg had, in 2014, a domestic fuel demand of: 365.255 metric tonnes/year. This is an EU average demand. Main airline sustainability goals The local airline in Luxembourg, Luxair, has some sustainability goals and scores +.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production biofuels in Luxembourg.


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3.20. Malta - Category 4 1. Policy

Obligation Stimulation Malta has the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED, and has obligated the market of distributors and importers of diesel and petrol. In 2014, Malta is a little behind schedule with a 4.7% share of renewable sources in the transport sector. Certificate System No trading scheme or system of certificates exist in Malta. Other Incentives

- Fuel excise duty does not hold for biofuels in Malta, which lowers the price gap between conventional fuels.

2. Local Production

Advanced Biofuel Producers No advanced biofuel producers exist in Malta. Feedstock Opportunity Score Malta has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Malta had, in 2014, a domestic fuel demand of: 103.401 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals Airmalta has no sustainability goals and scores 0.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Malta.


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3.21. Netherlands - Category 1 1. Policy

Obligation Stimulation The Netherlands are working towards the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED, and has obligated the market of distributors and importers of diesel and petrol. In 2014, the Netherlands are on schedule with a 5.7% share of renewable sources in the transport sector. Certificate System A ‘Bio ticket’ trading scheme exists in the Netherlands, this system is called ‘Hernieuwbare Brandstofeenheden (HBE’s). Fuel importers are obliged to have such bio tickets, they can choose whether to produce biofuels themselves to create bio tickets, or whether they buy biofuels from another organisation and therewith buy bio tickets. This system is the only system in the EU that provides producers of SAF the opportunity to get bio tickets, which can then be sold to obligated parties. This results in the possibility to cover the premium between fossil fuels and SAF and will therefore be the example for other EU Member States. Other Incentives

- Numerous other incentives exist in the Netherlands on financial stimulation of renewable energy generation.



- Neste Oil has a large production facility in Rotterdam, which is part of the Bioport Holland initiative in which SkyNRG, KLM, the Dutch Government, the Port of Rotterdam and Schiphol participate.

Feedstock Opportunity Score The Netherlands have a below average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand The Netherlands had, in 2014, a domestic fuel demand of: 3.448.387 metric tonnes/year. This is an above EU average demand. Main airline sustainability goals Air France – KLM has high ambitions to meet sustainability criteria and thus scores +++.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in the Netherlands.


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3.22. Poland - Category 4 1. Policy

Obligation Stimulation Poland has not obligated fuel importers and producers as they have been stimulating biofuels with the use of tax relief policies. After 2011 they stopped with this legislation as well. Currently the focus is on stimulating renewable electricity generation. Currently Poland has a 5.7% share of RES in the transport sector, in 2014. In 2011 this was 6.4% so current legislation does not seem to stimulate biofuel development sufficiently. Certificate System Poland has no certificate trading scheme in place to stimulate biofuels. Other Incentives

- Poland has an auction system in place to stimulate the projects with the best prospects for renewable energy generation.

2. Local Production

Advanced Biofuel Producers No advanced biofuel producers exist in Poland. Feedstock Opportunity Score Poland has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Poland had, in 2014, a domestic fuel demand of: 526.972 metric tonnes/year. This is an EU average demand. Main airline sustainability goals The local airline in Poland, LOT Airlines, has no significant sustainability goals and scores 0.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production biofuels in Poland.


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3.23. Portugal - Category 2 1. Policy

Obligation Stimulation Portugal was working towards the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED, and had obligated the market of distributors and importers of diesel and petrol until 2010, they reached a share of 5.3% RES but dropped to 0.4% right after the FQD banned soybean based biodiesel from the list of renewable feedstocks. In 2014, Portugal is back on 3.4% share of RES in their transport, which is well behind the targets. However, numerous policies are in place to stimulate biofuels (Hanson & Mendes, 2011; Trennepohl, 2013). Certificate System Companies introducing fuels on the Portugese markets are obliged to include biofuels. The system in Portugal to monitor this, is called: ‘Titulo de Biocombustiel’ (TdB’s). These biofuel entitlements are tradable units, if a company obliged to have TdB’s is missing these they get fined. Some technologies receive extra TdB’s per Toe produced biofuel, which is known as the double counting principle in other Member States (Global Agricultural Information Network, 2015). Other Incentives

- There is a large subsidy scheme to stimulate electric driving - There are partial and total tax exemptions for some of the biofuels.

2. Local Production

Advanced Biofuel Producers - IncBio is a large manufacturer of biodiesel from UCO, and has a history of producing

biofuel from other first generation feedstocks as well. Feedstock Opportunity Score Portugal has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Portugal had, in 2014, a domestic fuel demand of: 1.049.937 metric tonnes/year. This is an EU average demand. Main airline sustainability goals Tap Portugal has some sustainability goals and therefore scores +.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Portugal.


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3.24. Romania - Category 4 1. Policy

Obligation Stimulation Romania is working towards the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED, and has obligated the market of distributors and importers of diesel and petrol. In 2014, they reached a share of 3.8 % RES in their transport, which is behind the target. Obligations prescribe 5% biodiesel and 4.5% bioethanol blends. Certificate System No trading scheme or system of certificates exist in Romania. Other Incentives

- Some policies to enable renewable electricity generation, focus on electricity and very limited biofuel policies.

2. Local Production Advanced Biofuel Producers No advanced biofuel producers exist in Romania. Feedstock Opportunity Score Romania has a high above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Romania had, in 2014, a domestic fuel demand of: 206.313 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals TAROM has some substantial sustainability goals and thus scores ++.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Romania.


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3.25. Slovakia - Category 4 1. Policy

Obligation Stimulation Slovakia is working towards the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED, and has obligated the market of distributors and importers of diesel and petrol. In 2014, they reached a share of 6.9% RES in their transport, which is on track of reaching their targets. Certificate System No trading scheme or system of certificates exist in Slovakia. Other Incentives

- Biofuels are exempt of excise taxes. - Some policies exist to stimulate electrical generation from renewable sources.

2. Local Production

Advanced Biofuel Producers No advanced biofuel producers exist in Slovakia. Feedstock Opportunity Score Slovakia has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Slovakia had, in 2014, a domestic fuel demand of: 40.461 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals The local airline went bankrupt and has no sustainability goals and therefore no score.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Slovakia.


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3.26. Slovenia - Category 4 1. Policy

Obligation Stimulation Slovakia is working towards the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED, and has obligated the market of distributors and importers of diesel and petrol. In 2014, they reached a share of 2.6% RES in their transport, which is behind the schedule of reaching their targets. Certificate System No trading scheme or system of certificates exist in Slovenia. Other Incentives

- Biofuels are exempt of excise taxes. - Feed-In tariffs exist to stimulate electrical generation from renewable sources.

2. Local Production

Advanced Biofuel Producers No advanced biofuel producers exist in Slovenia. Feedstock Opportunity Score Slovenia has a below average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Slovenia had, in 2014, a domestic fuel demand of: 25.410 metric tonnes/year. This is a below EU average demand. Main airline sustainability goals Adria Airways has no sustainability goals and thus scores 0.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Slovenia.


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3.27. Spain - Category 2 1. Policy

Obligation Stimulation Spain was already working with obligations before the RED legislation came into place. They have created larger obligations to reach 10% RES in 2020. There is no specific support for biofuels that meet the criteria of Article 21(2) of the directive, this is the article about double counting waste stream biofuels. Spain is currently on a low share of 0.5% RES in the transport sector, this is probably due to the fact they do not take into account double counting, while the other MS are using this method to increase percentages. Certificate System Spain has a trading scheme, in which obligated parties need to have certificates to conform to the obligation rules. The National Energy Commission (NEC) manages this system, and will allow for the parties to transfer certificates while also acting as a control mechanism for the obligation. Other Incentives

- An investment system is in place for existing and future renewable facilities to receive a payment that covers the investment costs that an efficient and well-managed company will not be able to recover from the market.


- Abengoa is a large producer of biofuels and is situated in Salamanca with a facility. Feedstock Opportunity Score Spain has an above average score on feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand Spain had, in 2014, a domestic fuel demand of: 5.149.217 metric tonnes/year. This is an above EU average demand. Main airline sustainability goals Iberia has good sustainability goals and thus scores ++.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Spain.


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3.28. Sweden - Category 3 1. Policy

Obligation Stimulation Sweden is well above the renewable target for transport that builds up to 10% in 2020 as prescribed in the RED. In 2014 Sweden already reached a share of 19.2% RES in their transport sector. Since 2014 Sweden put out a quota on the fuel importers and producers to further enhance the biofuel development (Government offices of Sweden, 2009). Certificate System An extensive certificate trading scheme exist in Sweden for electricity. This system could be used as a starting point for biofuels, as the certificates for a kWh of electricity could be translated into Joules of biofuels produced. In order to reach this, changes in legislation need to take place. Both an opportunity and barrier is the fact that the certificates can be traded between Norway and Sweden, this implies a bigger market. However, also more legislation to include SAF as a ‘producer’ of these certificates. Other Incentives

- Biofuels are exempt of excise taxes. - A number of electricity certificate schemes to force electricity suppliers to include

renewable energy into their electricity mix. - There is also an emission trading scheme available for the energy generation industry.

2. Local Production

Advanced Biofuel Producers - Swedish Biofuels, focussing on aviation fuels work closely with SkyNRG. - Fortum is a producer of biofuels from wood based material.

Feedstock Opportunity Score Sweden has a below average score on feedstock opportunity, however it should be noted that this feedstock opportunity does not take the large wood reserves into account, which are significant in Sweden.

3. Fuel Demand Domestic Fuel Demand Sweden had, in 2014, a domestic fuel demand of: 874.215 metric tonnes/year. This is an EU average demand. Main airline sustainability goals The SAS has high sustainability targets and biofuel involvement +++.

4. Support from governmental Bodies (e.g. DoD) There is no specific governmental body involved to stimulate the production or wider distribution of Biofuels in Sweden, although the wood and paper industry are two strong industries who have a large interest in biofuel opportunities.


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3.29. United Kingdom - Category 2 1. Policy

Obligation Stimulation The UK has obligated the market suppliers (over 450.000 liters of fuel) under the Renewable Transport Fuel Obligation (RTFO). The market organisations can choose to either supply biofuel and earn certificates, buy the certificates from others who have supplied or pay the buy-out price. In 2014, the UK transport market has a RES share of 4.9%, which makes them little behind on schedule of the 10% target in 2020. Certificate System The RTFO works with a certificate scheme and is amended extensively since 2011 to stimulate advanced biofuels with double counting measures and mandatory sustainability criteria are set. As said, certificates exist which can be traded separately from the biofuels between obligated and non-obligated parties. Other Incentives

- The electricity market is also obligated with shares of renewable generated electricity - Feed in Tariff Schemes exist to stimulate sustainable electricity generation.

2. Local Production

Advanced Biofuel Producers - Solena GreenSky was an interesting project, however due to lack of financing failed to

get going. - In December 2014, the UK Department for Transport launched the Advanced Biofuel

Demonstration Competition to support the production of UK-based advanced biofuels. The Competition will provide up to £25 million in grant funding for major demonstration projects providing transformative and innovative solutions. Ricardo-AEA and E4tech have been appointed as delivery partners for the Competition and post-award monitoring.

Feedstock Opportunity Score The United Kingdom has a below average score for feedstock opportunity.

3. Fuel Demand Domestic Fuel Demand The United Kingdom has the highest domestic fuel demand of all member states; 11.364.889 metric tonnes / year. Main airline sustainability goals British Airways has extensive sustainability goals and therefore scores +++.

4. Support from governmental Bodies (e.g. DoD) No specific governmental body is involved in the biofuel development in the UK.


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3.30. Conclusion The country analysis shows the potential of each EU Member State to include SAF in the legislation to stimulate biofuels under the Renewable Energy Directive. Four broad categories can be distinguished from this analysis.

1. The first category consists of the MS in which the aviation opt-in is already included in

the legislation. This only holds for the Netherlands, no party has currently used the legislation yet, however SkyNRG is currently working on a project to prove the opt-in.

2. The second category entails MS that have a tradable certificate system in place for

biofuels. It is important to note that it must be possible to trade these certificates independently from the physical biofuel. As the idea of covering the price premium will not work when the certificates generated by producing SAF can’t be sold to obligated parties in the road transport industry.

3. The third category, includes MS with a mix of policies. Certificate systems for electricity generation or without tradable possibilities are included in this category. Also countries with a very large potential due to large local demand, an existing second generation biofuel company or an alternative policy to directly financially stimulate biofuels are included in this category.

4. The fourth and final category includes all member states without any specific biofuel policy and with low scores on the other criteria. This is the category furthest away from an aviation opt-in in the recent future.

Category 1 Category 2 Category 3 Category 4

The Netherlands Germany Belgium Austria

Ireland Croatia Bulgaria

Italy Denmark Cyprus Portugal Finland Czech Republic Spain France Estonia United Kingdom Sweden Greece Hungary Latvia Lithuania Luxembourg Malta Poland Romania Slovakia Slovenia


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Figure 8. Overview of member state potential to include the aviation opt-in

Conclusion The six member states in category two, have the biggest opportunity to implement the aviation opt-in into their current certificate systems under the Renewable Energy Directive. Therefore, these member states are further analysed in the in-depth section of this report. This does not mean that categories three and four will have no opportunity to implement SAF, however the current opportunity to make use of the RED legislation is lower and therefore these member states are not further analysed in this report.


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4. RED aviation opt-in member state analysis Each of the six high potential member states are analysed more in-depth to discover their aviation opt-in potential. The structure for each of the member states is similar. As each member state adopted the RED legislation differently, first the current obligation system for road transport is explained. Also, as the aviation opt-in is part of the ILUC amendment, the window of opportunity of the ILUC implementation deadlines are provided. This is followed by a description of how the current certificate system works and which stakeholders are involved in the member state. The analysis is finalised with a short indication of how the aviation opt-in could work in the respective member state.

4.1. RED aviation opt-in member state analysis – Spain 4.1.1. Obligation for road transport

Spain was already working with obligations before the RED legislation was established. However, Spain has currently a renewable energy source share in the road transport sector of 0.5%. This means Spain is behind schedule on reaching 10% in 2020. From January 2016 onwards, legislation changed to a general obligation for biofuels. Previously there were individual obligations for biofuels in petrol and diesel.

ILUC amendment Nearly all of Spanish biofuel production and consumption is produced with the use of food and energy crops as a feedstock. Therefore, Spain was not in favour of the 7% cap on ‘first generation’ biofuels stated in the ILUC amendment. However, now the ILUC amendment is accepted and implemented by the EU, Spain needs to change their directive accordingly. This transposition of the ILUC amendment, is in hands of the Ministry of Industry, Energy and Tourism (MINETUR). They will establish a proposal for the advanced biofuel objective, with the help of a public consultation period in the summer of 2016, to establish legislation before the 6th of April 2017. Implementation starts in September 2017.

4.1.2. Certificate System The obligation is verified in Spain with the use of certificates. In this certificate system obligated parties need to have certificates to show their compliance to the obligation. In Spain there are around 100 organisations obligated under the RED legislation, these can be categorized in one of three groups:

- Final fuel suppliers to the market - a fuel retailer who has imported fuels - a consumer who has imported fuels for own use

The Comisión Nacional de los Mercados y la Competencia (CNMC), issues and manages this system called SICBIOS. CNMC will control the (trading of) certificates while also acting as a control mechanism regarding the sustainability issues of the obligation. Figure 9 shows a schematic overview of how the certificates are generated in Spain. In the following this system is elaborated upon in more detail.

ILUC Implementation timeline Public consultation period Final legislation Implementation Summer 2016 06-04-2017 01-09-2017


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1. Statement of compliance (SoC) for each step in the supply-chain indicating that the mass balance rules and sustainability criteria have been met needs to be gathered by the certificate registrant.

2. A proof of supply to the end-user transport market needs to be shown to the CNMC by the registrant.

3. The obligated party is responsible to request for certificates, in order to do this, they have to hand over a set of documents regarding sustainability (as specified under sustainability). Including a verifier’s audit report stating that the mass balance rules and sustainability criteria have been applied throughout the supply-chain

4. CNMC provides the obligated party with their requested amount of certificates

Figure 9. Schematic overview of the road transport biofuel certificate system in Spain

Sustainability criteria Spain just recently changed its sustainability criteria, therefore both the old and new situations are briefly discussed. Previous situation

CNMC

Spanish biofuel certificate system

BIO-REFINERY

BLENDING&STORAGE

END-USE

Physicalfuelflow

Feedstock

Neatbiofuel

Blendedbiofuel

Blendedbiofuel

Administrativeflow

1

2

34

Independentaudit

Fossilfuel

FUELSUPPLIER/OBLIGATEDPARTY


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From January 2013 to January 2016, a special period previous to the transition period for the verification of the sustainability of biofuels applied in Spain. This meant that sustainability criteria were only indicative and not binding for the certification of biofuels. However, it was mandatory to provide the information on, type of biofuel and raw material as well as the country of origin of the biofuel and the raw material. Current situation From January 2016, obligated companies must submit more detailed information and documentation. Furthermore, the three main criteria as stated in the EU RED legislation need to be fulfilled:

- To be considered sustainable, biofuels must achieve greenhouse gas savings of at least 35% in 2016, 50% in 2017 50% and 60% in 2018. All life cycle emissions are taken into account when calculating greenhouse gas savings. This includes emissions from cultivation, processing, and transport (i.e. the full supply-chain).

- Biofuels cannot be grown in areas converted from land with previously high carbon stock such as wetlands or forests.

- Biofuels cannot be produced from raw materials obtained from land with high biodiversity such as primary forests or highly biodiverse grasslands.

The certificate is only issued to the obligated organisations when they provide the following documents to the CNMC:

- Provide information on: batch, biofuel type, volume, feedstock and country of origin of raw material and biofuel.

- Demonstrate compliance with the three main sustainability criteria through one of the voluntary schemes recognized by the EC. These schemes can be for example the RSB or ISCC certification.

Value One certificate is issued per tonne of oil equivalent (toe) of biofuel. On a monthly basis companies receive certificates, however only once a year the certificates are checked and made ‘definitive’, these definitive certificates are used to control whether the obligations are met. The all year-end is on the 21st of March, looking at the price history of certificates, certificates’ worth is fluctuating substantially; ranging from €200 - to € 763,- per certificate (December 2014 and February 2014 respectively, equivalent to € 210,- to € 802,- per metric tonnes). Special interest in Spain goes out to Biodiesel, for biodiesel to be certifiable, it must have been produced in a production plant that has been allocated an amount of biodiesel. Biodiesel will not be certified if it is produced in a plant that has not been assigned a quota or if the amount of biodiesel produced in a plant exceeds the assigned amounts. This system is however under revision and at the end of summer 2016 a decision to, change or stop with this system will be taken. Contrasting to other member states, no double counting exists in Spain in the current legislation, together with the ILUC implementation this might change in the future. A buy-out option is the final option for organisations to fulfil their obligation. However, it is not allowed to use the buy-out for their entire obligation. At least 50% needs to be fulfilled


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with actual certificates. After this the buy-out price is € 763 / certificate (toe biofuels). This means that this is also the maximum price certificates are traded for, as seen in February 2014. The money ‘raised’ in the buy-out fund is allocated among parties with surplus certificates. So a producer of biofuels who has a surplus of certificates and can’t put them through to next year or sell them to another organisation, can receive a share of this fund.

Trading certificates The certificates can be freely traded under the supervision of the CNMC, which registers transfers of certificates from one entity to another. There is no formally organised secondary market, thus transfers are arranged among organisations trough bilateral negotiations. This enables obligated organisations to fulfil their obligation by buying certificates instead of producing biofuels themselves. An obligated party is allowed to comply up to a maximum of 30% of next year’s obligation with certificates transferred from previous year.

4.1.3. Stakeholders The stakeholders are discussed in three categories, first the responsible governmental organisations are discussed, followed by the biofuel industry. The last discussed category is the airline industry. In Figure 10, an overview of the stakeholders is provided. This is followed by an in-depth description of the stakeholders and its responsibilities.


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Figure 10. Stakeholder overview Spanish biofuel industry

Government and Regulators - The Ministry of Industry, Energy and Tourism (MINETUR) is the responsible ministry

setting the biofuel obligation targets. MINETUR is also developing the legislation regarding biofuels in Spain and is therefore the body responsible for including the aviation opt-in.

- Under MINETUR, the Institution for the Diversification of Energy (IDEA) is responsible

for the executing and creation of stimulating mechanisms to reach energy goals and targets. In this role IDEA is subsidizing new technologies and investigating new possibilities for more efficient use of energy. IDEA is also closely involved in developing new legislation for the biofuels.

Biofuel Industry

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- Where MINETUR and IDEA are creating the legislation, the Comisión Nacional de los Mercados y la Competencia (CNMC) is a governmental organisation, however acts independently as the national regulator for competition and is in the case of biofuels responsible to control the certificates through the Information System for Biofuels (SICBIOS).

- The Ministry of Agriculture, Food and Environment (MAGRAMA) is responsible for the

Emission Trading Scheme (ETS) and Carbon Fund, not directly involved in the biofuel legislation, however very closely related. And this ministry will have a role regarding the ILUC implementation as their focus is on biodiversity, climate change and environmental quality.

Biofuel Industry Feedstock main feedstocks used in the Spanish Biofuel industry are the feedstocks used for Fatty Acids and Esters technologies (FAME) in biodiesel, such as: Palm Oil, UCO, Soy oil, animal fat, rapeseed, canola and sunflower oils. Olive pomace oil is a potential feedstock interesting for Spain and topic of some studies, however this is not in place yet. SkyNRG is investigating the possibilities of using this feedstock for setting up a regional supply-chain. The companies involved in the feedstock area are:

- Bioplat - the Spanish biomass technology platform. - Geregras - UCO managers and edible fats national association. - Camelina company España - producer of camenila oil for the production of bio-jet. - Grupo RAC - Brazilian company with section in Spain for UCO collection. - Sacyr - Pomace Olive Oil producer.

Biofuel production industry Due to the single quota mandate, which combines the biodiesel and bioethanol blending quotas, the fear existed that there would be an over-reliance on biodiesel from FAME facilities in Spain. Currently this does not seem to happen as the HVO/HEFA biofuels are all produced within Spain, only incidentally biofuel is imported. The Association of Renewable Energy Companies (APPA) brings together all biomass as well as specific biofuel companies together. Some of the companies active in biofuel production are listed below. A complete overview of facilities and companies is in hands of SkyNRG but would be too extensive for this study.

- Abengoa – Large worldwide producer of biofuels as well as solar technolgoies - Infinita Renovables – Biodiesel producer using FAME technology is part of Musim Mas

and has two facilities in Spain. - Iniciativas Bioenergéticas – Biodiesel producer using FAME technology - Biocom Energia – Producer of advanced biodiesel from vegetable oils and animal fats. - Ecomotion Biodiesel – Producer of biodiesel from rapeseed, with own crushing facility. - Acciona Bunge – Biodiesel facility in Bilbao

Oil companies The Spanish Association of Petroleum Products Operators (AOP), is the overarching organisation for petroleum products.


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- Cepsa – Regular oil major, HVO producer - Repsol – Regular oil major, HVO producer - BP – Regular oil major, HVO producer

Aviation industry Airports and Logistics

- SENASA - Airline association under the ministry of finance and administrative order - AENA Group – organisation in which all airports in Spain are united - OBSA - Observatory of Sustainability in Aviation (but directly connected with - SENASA) - AESA – State body ensures civil aviation standards in Spain. - INTA – National Institute for Aerospace Technology (in EU Biofuels platform)

Airlines

- Iberia - Vueling - Pullmantur - Air Europe

4.1.4. Possible voluntary opportunity to include Jet Fuel Spanish biofuel certificates are generated at the fuel supplier. The steps 1 – 4 can therefore be similar to the road transport sector. However, as the certificates are worthless for the jet fuel supplier, the certificates can be sold to the road transport fuel supplier. Therewith covering part of the price premium of SAF. In the following the steps are explained in more detail.

1. Statement of compliance (SoC) for each step in the supply-chain indicating that the mass balance rules and sustainability criteria have been met needs to be gathered by the certificate registrant.

2. A proof of supply to the end-user transport market needs to be shown to the CNMC by the registrant.

3. Besides their own proof of sustainability, the registrant also has to include a verifier’s audit report stating that the mass balance rules and sustainability criteria have been applied throughout the supply-chain.

4. The certificate registrant can then request the certificates, in order to do this, they have to hand over the set of documents (step 1) regarding sustainability (as specified under sustainability

5. CNMC provides the obligated party with their requested amount of certificates 6. As the jet fuel supplier does not need the certificate for an obligation they sell them to

the obligated party. 7. The road transport fuel supplier, the obligated party, hands over the certificates to the

CNMC and therewith fulfils its obligation.


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Figure 11. Hypothetical schematic representation of the Spanish certificate system including the aviation opt-in

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4.2. RED aviation opt-in member state analysis – Portugal 4.2.1. Obligation for road transport

Portugal is working towards the renewable target for transport that builds up to 10% in 2020 as prescribed in the Renewable Energy Directive. To reach this target, Portugal obligated the market of distributors and importers of diesel and petrol, they reached a share of 5.3% in 2010, but dropped to 0.4% when sustainability criteria came into play. In 2014, Portugal is back on a 3.4% share of renewable energy sources in the transport sector. Still behind on the targets for reaching the 10% share in 2020.

ILUC amendment Almost all biofuel activity is based on first generation biodiesel in Portugal. As Portugal also has a large farming sector, they were relatively opposed to any significant limitations on first generation biofuels. This resulted in a negative view on the ILUC amendment. However, now the ILUC legislation is accepted by the EU, Portugal needs to change their legislation accordingly. Portugal is currently working with the responsible ministries; Ministry of economic, Ministry of Environment and Ministry of Agriculture, Forestry and Rural Development, the Entidade Nacional Para O Mercado de Combustiveis (ENMC) and the Directorate General for Energy and Geology (DGEG) on the renewed ILUC implementation, this is open for input from the industry in the summer of 2016. Legislation will be implemented in 2017.

4.2.2. Certificate system The obligation set out in Portugal is controlled with a certificate system. Obligated parties can prove their compliance with the biofuel obligation by having biofuel certificates; so called: Titulo de biocombustivels (TdBs). The obligated parties entail “all entities that incorporate fuels on the market for end consumption for the road transport sector”. The Entidade Nacional Para O Mercado de Combustiveis (ENMC) is responsible for managing and controlling the system of obligation, including the trading of certificates. The ENMC is an independent (semi-public) organisation that is responsible for “the use of biofuels promotion, encouraging the greenhouse gases emissions reduction and contributing to the energy supply security reinforcement in Portugal.” The Directorate General for Energy and Geology (DGEG), was previously responsible for the entire certificate system, ENMC has taken most of its role now. However, DGEG is still involved with the smaller producers (PPD) as the certificates generated by these parties (approximately 3% of the total) are auctioned to obligated parties. A final entity in the certificate system is the Entity Compliance Coordinator of Sustainability Criteria (ECS), which is part of the ENMC, is the body responsible for verification of the sustainability criteria and issues the certificates.

ILUC Implementation timeline Public consultation period Final legislation Implementation Summer 2016 End 2016 2017


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In Figure 12 the certificate system is shown graphically. Interesting to note from the Portuguese system is that the producer of the biofuel, i.e. the bio-refinery is the place where TdBs are generated. This in contrast with e.g. the Dutch system where there is no fixed place of certificate registration. In the following this system is discussed more specifically:

1. The producer of the biofuel hands over documents proving the sustainability of the biofuel and feedstock it is made from. This information is send to ENMC, who checks it.

2. ENMC checks the documents and issues a TdB with the biofuel, when double counting is applicable the respectable number of TdBs are issued.

3. The TdBs are moving alongside the fuel to the fuel supplier. 4. The obligated party proves that the fuels are put on the final transport market, and

therewith the obligated party fulfils their mandate.

Figure 12. Schematic overview of the road transport biofuel certificate system in Portugal

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Portuguese biofuel certificate system

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Sustainability criteria The sustainability criteria are in line with the Renewable Energy Directives sustainability criteria:

- To be considered sustainable, biofuels must achieve greenhouse gas savings of at least 35% in 2016, 50% in 2017 50% and 60% in 2018. All life cycle emissions are taken into account when calculating greenhouse gas savings. This includes emissions from cultivation, processing, and transport (i.e. the full supply-chain).

- Biofuels cannot be grown in areas converted from land with previously high carbon stock such as wetlands or forests.

- Biofuels cannot be produced from raw materials obtained from land with high biodiversity such as primary forests or highly biodiverse grasslands.

These Green House Gas reduction is checked in the entire supply chain. The proof of compliance of the GHG criteria is checked by using a mass balance system. The Land Use criteria is only checked for the feedstock which needs to be provided by the biofuel producer. As was shown in Figure 12.

Value The value of 1 TdB is one tonne of oil equivalent (toe) of biofuel put on the market. Three types of TdBs can be distinguished, these TdBs are all worth the same value, this also ensures that TdBs can be traded amongst and count to all obligated parties. In other words: a gasoline obligation can be fulfilled with TdB-O’s.

- TdB-G correspond to a TdB issued for a gasoline substitute biofuel. - TdB-D correspond to a TdB issued for a diesel substitute biofuel. - TdB-O correspond to a TdB issued for another fuel substitute biofuel.

In the case of raw materials (waste or debris) used in the production of biofuels 2 TdBs instead of 1, are issued per Toe of biofuels put on the market. This also holds for biofuels produced with non-food cellulosic material or lignocellulosic material. Unique in Portugal are the extra TdBs for biofuels produced from domestic non-food raw materials. These receive 1.3 TdB per Toe produced. Each Toe of biofuel produced out of domestic agricultural raw materials is granted with 1.1 TdB. As this is national legislation, the EC does not recognize these extra TdBs. Therefore, the extra TdBs received from domestic raw materials is just valid at the domestic level and cannot be reported to the EC as part of the national obligation. A compensation fine does exist when the obligated party does not deliver the prove of compliance with the obligated target. The height of the fine is not fixed and depends on the seriousness of the offense and can range from € 2.500 to € 44.891. The ‘income’ from these fines are distributed for 70% to the Portuguese Carbon Fund and 30% to the Energy Efficiency Fund.

Trading certificates When an obligated party does not want to / can not produce biofuels themselves, it is possible to buy certificates from another obligated party who has too many or from an independent biofuel producer. The certificates can be freely traded under the supervision of the ENMC, which registers transfers of certificates from one entity to another. There is no formally


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organised secondary market, thus transfers are arranged among organisations trough bilateral negotiations or through economic agents who obtain large amounts and sell them to obligated parties. This enables obligated organisations to fulfil their obligation by buying certificates instead of producing biofuels themselves. Certificates can be transferred to the next year, without any cap. However, tickets are only valid for two years. So no long-term banking is possible.

4.2.3. Stakeholders The stakeholders are discussed in three categories, first the responsible governmental organisations are discussed, followed by the biofuel industry. The last discussed category is the airline industry. Figure 13 shows the overview of stakeholders, this is followed by an thorough description of the stakeholders.

Figure 13. Stakeholder overview Portuguese biofuel industry.

Government and Regulators - Ministry of Economy – Responsible for economic regulations and the body under

which ENMC operates.

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- Entidade Nacional Para O Mercado de Combustiveis (ENMC) - The national authority for the fuel market, this organisation is the regulator for fossil fuels and biofuels. In this role the ENMC is also responsible for the TdB System.

- Entity Compliance Coordinator of Sustainability Criteria (ECS) – Entity which is directly connected to the ENMC, responsible for checking sustainability compliance and the issuing of certificates.

- Directorate General for Energy and Geology (DGEG) – The licensing energy authority, including biofuels, responsible for setting the obligations and checking whether the obligated parties complied with their obligations.

- Ministry of Agriculture, Forestry and Rural Development – Involved in the ILUC implementation and in general the closest ministry to the legislation.

- Ministry of Environment – Together with the ministry of agriculture close to ILUC implementation, also responsible for the emission trading scheme.

- Portuguese Environment Agency (APA) – Could be a key contact with knowledge on legislation, Carbon Funds etc.

- Trade & Investment Agency of Portugal (AICEP) – As an independent organisation a lot of knowledge on the fuel and aviation side to help get access for foreign companies, like SkyNRG, to get in touch with the right stakeholders

- Civil Aviation Authority (ANAC) – The aviation authority responsible for aviation airport legislation, noise control, environmental legislation, etc.

Biofuel Industry Feedstock The Portuguese biofuel sector mainly consists of biodiesel production. This biodiesel production is heavily reliant on imported raw materials. Domestic oilseeds production comes down to olive oil and sunflower oil, both of them being primarily intended for the food market. The Portuguese biofuel industry is trying to increase domestic and local production of raw materials in order to reduce the country’s dependency on imported feedstock. The feasibility of this possibility, especially regarding the first generation fuels has been questioned regularly. The deficit in domestic oil production for the biodiesel is compensated by imports of oils (palm oil, soybean oil or other Vegetable oils) or oilseeds (mainly rapeseed and soybean) to be crushed in the country. Soybeans have been the biggest feedstock in the past, however nowadays rapeseed is the dominant feedstock. In Portugal, the big feedstock processors are Sovena and Iberol, owning the majority of the crushing capacity. On the advanced feedstock side, there are some organisations that gather Used Cooking Oil (UCO) for biodiesel production in Portugal.

- Oleotorres – Uses used cooking oil to make biodiesel, fats as well as candles and other products

- Ambióleo – UCO gatherer and refining to biodiesel and other industrial products. - Reciclimpa – Is gathering UCO by cleaning customers, restaurant fryers or large

vegetable oil containers.


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Biofuel production industry - Associacao Portuguesa de Produtores de Biocombustiveis (APPB) – Organisation for

the biodiesel producers, as an organisation they are the spokesman for the entire sector. Also they try to lobby around the government and spread information about biodiesel in general to inform the public.

- Associacao Portuguesa de Empresas Petroliferas (APETRO) – This organisation represents all Portuguese oil companies, including both the large ones, Cepsa, BP, Petrogal and smaller OZ Energy and de Rubis. APETRO is seen as a very important partner in the decision-making process with regards to the oil sector.

Oil Companies

- Galp Energia – Oil Company also refining jet fuel, biggest supplier of jet fuel. - Prio Energy – Oil company with a biodiesel plant, first to use UCO as a feedstock in

Portugal. - Repsol (Bio-ETBE) – Oil company with bioethanol and biodiesel activities also activities

to develop jatropha and algae. - OZ Energia – New oil player jet-fuel included Lisboa, Porto e Faro - Iberol – Oil company and owner of biodiesel plant

Aviation Industry Airports and Logistics

- ANA Group – Association under which all airports of Portugal are united; integrated in the French VINCI Airports Group.

- CLC - Companhia Logística de Combustíveis S.A. – Manages the only oil products pipeline in Portugal (65% Galp, 15% BP Portugal, S. A., 15% Repsol Portuguesa, S. A. e 5% Rubis Energia Portugal, S. A)

- Takargo Railcargo – The rail cargo organisation responsible for the transport of jet-fuel from Sines transported until Loulé by rail operated by Takargo (Mota-Engil),

Airlines - TAP Portugal – Tap is the local airline based on Lisbon Portela Airport - SATA Azores – Portuguese airline for the Azores region.

4.2.4. Possible voluntary opportunity to include Jet Fuel The Portuguese system is slightly different to the Dutch blueprint, as the certificates are generated at the producer. This does not mean it is impossible to implement the aviation RED opt-in. Figure 14 shows how the opt-in could be implemented. The following steps take place when a TdB is generated with SAF.

1. The bio-refinery can generate the ticket similarly to the road transport situation. First the bio-refinery provides the needed sustainability documents to the ENMC.

2. The ENMC checks the sustainability and issues the certificates 3. The ticket is useless for the jet fuel supplier, as he is not obligated. Therefore, the

ticket can be sold to the road fuel supplier, who is obligated under the RED 4. The obligated party hands over the TdBs to the ENMC to fulfil the obligation


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Figure 14. Hypothetical schematic representation of the Portuguese certificate system including the aviation opt-in

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4.3. RED aviation opt-in member state analysis – Ireland 4.3.1. Obligation for road transport

Ireland has as many other countries obligated the distributors and importers of diesel and petrol to reach the 10% renewable energy share target in 2020. Since 1st January 2013, the biofuel obligation has been increased to 6 litres in every 100 litres. This ratio equates to 6.4% of petroleum-based motor fuel placed on the market. In 2014, Ireland reached 5.2% which shows that Ireland is slightly behind their RED implementation schedule.

ILUC amendment Ireland is as other countries working towards an inclusion of the ILUC legislation. The National Oil Reserves Agency (NORA) is the organisation responsible for the administration of the Energy (Biofuel Obligation and Miscellaneous Provisions) Act 2010. The NORA is an independent statutory body created under the Department for Communications, Energy & Natural Resources. Currently there is no indication that Ireland is working on the ILUC implementation and the only public consultation period that is announced, is ‘planned for 2016’

4.3.2. Certificate system Ireland previously had a Mineral Oil Tax Relief Scheme (MOTR) in place to stimulate biofuels. Since 2011 this system is replaced by a certificate system known as the Biofuel Obligation Scheme (BOS). This certificate scheme is in place to control whether the obligated parties fulfil their obligation. The parties obligated under the RED legislation in Ireland are “all oil companies and oil consumer liable to pay the NORA Levy”. In other words: the party that puts the petroleum fuel on the market carries the Biofuel Obligation. The NORA is responsible to administer this system. NORA has engaged consultants (a consortium of Byrne Ó Cléirigh and LHM Casey McGrath – with BÓC as the lead consultant – hereinafter referred to as BÓC-CMG) to administer the Scheme. SiAs for the Dutch system, it is not important how many BOS certificates are generated by the party but it is the number of BOS certificates held in each party’s account at the end of the year which determines whether the obligation is met. The obligation period is the calendar year so runs from the first of January – 31st of December. NORA automatically opens a 'biofuel obligation account' for each obliged party to manage the issuance, transference and cancellation of biofuels certificates. A producer or supplier of fuels that is not obligated might also open an account, this party has to request this. Such accounts need to be accompanied by a tax clearance certificate. The certificate system is shown graphically in Figure 15, in the following a more detailed explanation on this system is provided. The certificate registrant can either be the producer or supplier of the biofuels. The same rules apply for both when registering for BOS certificates. Therefore, the figure shows a separate ‘registrant’, in reality this is either the ‘bio-refinery’ or the ‘fuel supplier’.

ILUC Implementation timeline Public consultation period Final legislation Implementation ‘Planned for 2016’ Unclear 2017


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1. The registrant has to show the sustainability of the entire supply-chain by filling in the UK Carbon Calculator.

2. An independent verification report is needed and should be obtained prior to registering for the BOS certificates.

3. Both the sustainability statements and verification report is handed over to NORA 4. In return the certificates are provided to the registrant. 5. If the registrant is the fuel supplier, he keeps them, as the fuel supplier is also the

obligated party. If the BOS certificates are registered at the bio-refinery the certificates are sold with the fuel to the fuel supplier, who can then fulfil the obligation.

6. The obligated party shows, at the end of the year, the fulfilment of its obligation.

Figure 15. Schematic overview of the road transport biofuel certificate system in Ireland

Sustainability Criteria In 2014 new sustainability criteria for biofuels are implemented by the Irish government in line with the Renewable Energy Directive’s sustainability criteria.

- Green House Gas emission savings of biofuels in comparison with the fossil fuel baseline. These emission targets are increasing: Before 2016: 35%, 2017: 50% and 2018: 60%.

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- Specific requirements based on the feedstock. Feedstock should not be obtained from land previously a primary forest, a nature protection area, highly biodiverse grasslands, wetland, peat land.

The GHG criterion is checked using a mass balance system, where the different feedstocks used for the biofuel production, are specified to determine the GHG savings. NORA further, accepts the sustainability criteria as prescribed by the RED. These criteria are as strict as prescribed in either:

- Compliance with any national scheme developed by a competent authority. - A bilateral or multilateral agreement concluded by the EC with a third country, referred

to in the RED. - A voluntary national or international scheme recognised by the EC under the RED.

Value A BOS certificate is issued for every litre of biofuel. There is no distinction for biofuels produced as diesel or ethanol. All certificates are considered the same and can be traded among different categories. Two BOS certificates will be issued for every litre of biofuel when they are produced from biodegradable waste, residue, non-food cellulosic material, ligno-cellulosic material or algae. In such cases, prior to issuing the double-counted certificates, NORA is obliged to consult with EPA, NSAI, SEAI and the Minister for Environment, Heritage and Local Government to ensure that the stricter sustainability regulations for these feedstocks are met. A compensation fine exists when the obligated party does not deliver the prove of compliance with the obligated target. The fine for not having the right amount of certificates at the end of the year, is currently € 0,45 per litre.

Trading Certificates The trading of certificates is a commercial matte between the buyer and the seller in Ireland. The BOS certificates can be transferred between BOS account holders, independently of the biofuel. To make it easier for buyers, NORA issues quarterly statements of accounts. As the trading works as a bilateral agreement between the parties, the price will be market driven. This enables obligated organisations to fulfil their obligation by buying certificates instead of producing biofuels themselves. An interesting note compared to other member states’ system is that certificates cannot be traded until the end of the year. Therefore, it’s impossible to know how much the certificates will be worth until the end of the year. This might be the reason that local biodiesel production has decreased since the BOS system replaced the MOTR system. As large fuel distributors choose to pay the low fine for the buy-out instead of buying the certificates from other parties. Obligated parties are allowed to fulfil up to 25% of their mandate with certificates of the previous year.


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4.3.3. Stakeholders The stakeholders are discussed in three categories, first the responsible governmental organisations are discussed, followed by the biofuel industry. The last discussed category is the airline industry. In Figure 16, an overview of the relevant stakeholders is provided.

Figure 16. Stakeholder overview of the Irish biofuel industry

Government and Regulators - Department for Communications, Energy & Natural Resources (DCENR) –

Governmental ministry responsible for energy and oil legislation, NORA operates under this department.

- Department of Transport, Tourism and Sport (DTTAS) – Has the task of transposing the biofuel directive, a.o. the ILUC directive.

- National Oil Reserves Agency (NORA) – Manages conventional oils, as well as the administrator of the BOS system, regulating the certificates and controlling the obligated bodies.

- Sustainable Energy Authority of Ireland (SEAI) – Ireland’s national energy authority under the sustainability Energy Act 2002. SEAI is a governmental organisation to develop Ireland’s low carbon and energy efficiency activities.

Biofuel Industry Feedstock The Irish biofuel production industry is small. The biodiesel production that is taking place locally is done with mainly oilseeds, tallow and used cooking oil (UCO). There are a number of collectors and distributors of UCO in Ireland:

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- Frylite – Waste oil collector and distributor of vegetable oils to restaurants in Ireland. - MT Oils – Waste oil collector who transports all their UCO to the Green Biofuels Ireland

biodiesel facility. Irish agricultural is expensive; Irish Biofuels claim: “It is the intention of the Company to import raw material (a.o. used cooking oil) from suppliers throughout Europe.” It is also stated in a report of the department of agriculture that feedstock prices are high, infrastructure is inadequate and importing B99 biodiesel is very cheap in Ireland, resulting in a low demand for local biodiesel production and its feedstock. Biofuel production industry

- Irish Bioenergy Association (IrBEA) – Organisation to promote bioenergy industry in Ireland. IrBEA represents all stakeholders from the Bioenergy sector. Affiliated to AEBIOM, the European Biomass Association.

- Green Biofuels Ireland Ltd. – 30.000 tonnes per year facility in New Ross. Leading Biodiesel facility in Ireland, from only waste feedstocks: UCO and animal fats.

- Irish Biofuels Production Ltd. – 20.000 tonnes per year facility in Wicklow Port. Producing biodiesel from various feedstocks, mainly UCO.

Oil Companies The traditional oil industry is small in Ireland, there is only one relatively small refinery operated by Phillips 66 in Cork, Ireland.

- Petrogas – Focus on oil distribution through filling stations in Ireland and the UK. - San Leon Energy – Oil and gas exploration company and leading in Europe on Shale gas

exploration.

Aviation Industry Airlines

- Aer Lingus – Oldest airline headquartered in Dublin, limited sustainability goals. - Ryanair – Budget airline, has a pure cost focus and no sustainability goals.

Airports and Logistics No oil pipelines exist and transport of oil products Is by road and rail. Local refineries are mainly located in the south, near Cork. Dublin airport is mainly supplied by ship and rail.

- Dublin Airport – 19 million passengers a year, stated owned airport under the DAA

4.3.4. How could the opt-in work? The system in Ireland is very similar to the Dutch blueprint, as either the producer or supplier of the fuel can be the registrant. The certificate system is shown graphically in Figure 17, on the left side the existing road transport system is shown and on the right side the possible jet fuel flow is shown. The certificate registrant can either be the producer or supplier of the biofuels. The same rules apply for both when registering for BOS certificates. Therefore, the figure shows a separate ‘registrant’ in reality this is either the ‘bio-refinery’ or the ‘fuel supplier’.

1. The registrant shows the sustainability of the entire supply-chain by filling in the UK Carbon Calculator.


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2. An independent verification report is needed and should be obtained prior to registering for the BOS certificates.

3. Both the sustainability statements and verification audit report are handed over to NORA when applying for the BOS certificates.

4. In return the certificates are provided to the registrant. 5. As the certificate registrant on the jet fuel side is not obligated, the BOS certificates

are sold to the obligated party in the form of the road transport supplier. 6. This obligated party hands over the certificates to NORA at the end of the year, and

therewith fulfils its obligation.

Figure 17. Hypothetical schematic representation of the Irish certificate system including the aviation opt-in

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4.4. RED aviation opt-in member state analysis – Italy 4.4.1. Obligation for road transport

Italy transposed RED Directive by means of the Legislative Decree no. 28 of 3 March 2011, according to which renewable sources are expected to cover 17% of gross final energy consumption in 2020 and at least 10% of final energy consumption in transport. Moreover, according to the Decree, as from 1st January 2012, biofuels used in transport and bioliquids and those used for the production of electricity will be counted for the achievement of the 10% national targets and will have access to support schemes only if they meet the sustainability criteria set out in the implementing measures of Directive 2009/30/EC of 23 April 2009 (Art. 38, comma 1)7. The GSE (Gestore Servizi Eneregetici)8 accredited by the MISE (Ministry for Economic Development) issues the certificates on an annual basis. Italy has currently reached a 4.5% use of renewable use in transport, a little behind schedule the 10% goal by 2020. Moreover, in November 2014, Italy became the first EU MS to mandate the use of advanced biofuels. In fact, an advanced biofuels blending mandate, for waste and non-food feed stocks biofuels, at 0.6% by 2018 and 1% by 2022, made Italy the first EU country to set a legally binding mandate for advanced biofuels. From January 2018 gasoline and diesel shall contain at least 1.2% advanced biofuel, rising to 1.6% by 2020, and 2% by 2022.

ILUC Implementation A public consultation in which the aviation opt-in could be suggested, takes place in June – July. As Italy was the first to mandate the use of advanced biofuels in the EU, their interest in new decarbonisation opportunities is large.

4.4.2. Certificate System The Italian government has combined two instruments to support biofuels: 1) a tax reduction (excise reduction) and 2) a trading system of biofuel certificates (CICs).

1) The first measure was aimed at reducing the final cost of biofuels. It was a total exemption in 1995 and it became a reduction of excise in 2006 for 250 thousand tons until 2009. The reduction of the excise duty has been changed by Law 191/2009 which assigns 18 thousand tons of biodiesel to be distributed among biodiesel plants. This measure ended on December 31, 2010 (Adele Finco & Franco Angeli 2013).

2) Obligated subjects can also fulfil the obligation buying the so-called biofuel immission certificates (“Certificati di Immissione in Consumo” - CICs). GSE, accredited by the MISE (Ministry for Economic Development) issues these certificates on an annual basis. Each certificate verifies that 10 Gcal of biofuels have been made available for consumption. The certificates are tradable, so it is possible

7 See: Art. 38. Criteri di sostenibilità per i biocarburanti e i bioliquidi – Sustainability criteria for biofuels and bioliquids. 8 GSE: Gestore dei Servizi Energetici S.p.A. is the state-owned company that promotes and supports renewable energy sources in Italy.


http://www.gse.it/en/company/Pages/default.aspx


for those liable for the obligation to make biofuel available to fulfil the legal obligation by buying certificates from other parties who have too many. The certificates are traded through bilateral negotiations and subsequent notification to the MIPAAF certification system.

According to the National Renewable Energy Action Plan, the intention for the future is to take action mainly through the obligatory minimum quota, in line with the sustainability criteria and the development of second and third generation biofuels. The obligated subjects (OSs), namely the parties who release for consumption gasoline and diesel to be used for motor transport, have to mix them with a well-established amount of sustainable biofuels. Both economic bodies as well as fuel suppliers are obligated under the mandate. Economic bodies are defined as those subjects based in the EU or in a third country that provide (either free of charge or under payment) feed stocks, intermediate products, waste and/or other materials and fuels for the production of biofuels and bioliquids to be marketed in the EU. The obligation, until 2013, was calculated on the basis of the calorific value of the fossil fuels released in the previous year, while from 2014 is based on the fossil fuels released in the current year. This system of certificates is shown in Figure 18, the verification of the sustainability criteria for biofuels and bioliquids is ensured through a system of traceability throughout the supply-chain (flow 1). As from January 2012, the economic operators of the production chain of biofuels and bioliquids, whether they are produced in EU and in third countries, who intend to join this system, must be subject to initial and periodic audits by certification bodies accredited by the single certification body, ACCREDIA, through its certification and inspection department (flow 2). Both the proof of sustainability and the check of accredia are provided to the GSE (flow 3). Consequently, the GSE issue the CICs to the obligated party (flow 4). The obligated party shows on its turn the CICs at the end of the obligation period to the GSE and therewith fulfils its obligation (flow 5).


Figure 18. Schematic overview of the road transport biofuel certificate system in Italy

Sustainability criteria These criteria relate to the nature of the land where the feedstock is grown and are aimed at preventing direct land-use change of areas of high carbon stock and high biodiversity value for the production of biofuels, as well as setting minimum greenhouse gas emission savings compared to fossil fuels. To verify compliance with the sustainability criteria, all parties involved in the production chain of the biofuel must adhere either to:

- the National System of Certification of Sustainability (Decree of the Ministry for the

Environment, Land and Sea of 23 January 2012); or

- a voluntary system (as set out in article Art. 7b Directive 2015/1513 amending FQD

(98/70/EC) and the RED (2009/28/EC); or

- Bi-lateral or multilateral agreement concluded by the European Union with third

countries and recognized by the European Commission (van Grinsven & Kampman

(20165).

As from 2012, a biofuel must comply with the following sustainability criteria, in order to be granted financial subsidies:

- Reduction of GHG emissions – the entire supply chain and consumption of biofuels

(from the feedstock to the final users) must guarantee a reduction in the GHG

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emissions in comparison with the use of fossil fuels. This reduction must at least

amount to 35% (as of 2013 for biofuels produced in factories operational since 2008).

The reduction-level will rise to 50% in 2017 and 60% as from 2018 (for biofuels

produced in factories operational as from 2017).

- Feedstock materials must not be derived from lands which have high biodiversity value

or lands with high carbon stock.

- If the feedstock materials are produced in the EU, they must comply with the standards

set out in Regulation 73/2009/CE as regards agricultural and environmental

conditions.

- Biofuels derived from waste other than agricultural/fishery/forestry must comply with

the first criteria listed above.

Value The price of a CIC in 2013 was about 400/450 €. A double-counting provision is in place. According to Legislative Decree No 28/2011 transposing Directive 2009/28/EC, parties who demonstrate that they have released for consumption biofuels produced from waste and waste by-products, algae and materials of non-food origin including cellulosic and ligno-cellulosic material shall be entitled to a certificate of release for consumption once they have released a quantity of 5 Gcal (rather than 10 Gcal) of such biofuels. Such release for consumption can thus be deemed to count twice the release for consumption of other biofuels. No buy out price is in place in Italy but a compensation fine applies when the obligated party does not deliver the certificate of compliance with the obligated target. Failure to fulfil the obligation by the Obligated Subjects implies the payment of a penalty of a value between 600 and 900 €/CIC depending on the extent of the failure.

Trading certificates In fulfilling their obligation, liable parties can purchase CICs from parties with certificates surplus to their own requirements. To fulfil the requirement, the Obligated Parties can, therefore, enter into biofuel consumption or purchase CICs from Parties with a higher number than in their obligations. For this purpose, the GSE has created a specific platform (BIOCAR) through which operators can exchange certificates. Verification procedures are carried out on a periodical basis. The validity of the certificate is of 1 year.

4.4.3. Stakeholders Government and regulations

- In Italy the competence for the ILUC Directive, amending Directive 98/70/EC (FQD) and Directive 2009/28/EC (RED), is split between the Ministry for the Environment Land and Sea and the Ministry of Economic Development (both under the coordination of the Executive).

Biofuel Industry Feedstock The most commonly used feedstock for aviation biofuels in Italy is palm oil. The renewable sources mostly used are mainly based on biofuels (biodiesel, biomethane, bioethanol,


ETBE36), either pure or blended with fossil fuels. The feedstocks used for the 2nd generation biofuel chain are above all the lignocellulose ones. M&G/Chemtex in Italy is building the largest world lignocellulosic plant in Crescentino (Vercelli, Piedmont Region) based on the proprietary innovative PROESATM technology (a new research center fully devoted to this technology has been established and operated since 2008) Oil major Eni has recently launched a diesel blend containing 15% vol. of hydrotreated vegetable oils (HVO) as a Renewable Diesel Fuel produced at its Porto Marghera plant. The product, Eni Diesel +, is to be available at 3,500 stations nationwide. Biofuel Industry

- Enel Group dedicated to developing and managing energy generation from renewable sources at the international level.

- Biofuels Italia - Italian Biofuels Technology Platform of the Bologna University aimed at fostering a network of public and private stakeholders able to accelerate and implement the response to the needs of society and consumers in the biofuel field in Italy, fostering the transfer of knowledge and innovation to the industrial world.

- ENEA – Italian National Agency for new Technologies which focuses on second-generation biofuels such as lingo-cellulosic materials such as, respectively, gasification into hydrogen and carbon oxide, and the fermentation of carbohydrates into ethanol, as well as the production of hydrogen from fermentation of humid biomass and biofuels from microalgae cultures.

- ENI - Ente Nazionale Idrocarburi engaged in oil and natural gas exploration, field development and production, as well as in the supply, trading and shipping of natural gas, LNG, electricity, fuels and chemical products. Through refineries and chemical plants, ENI processes crude oil and other oil-based feedstock to produce fuels, lubricants and chemical products that are supplied to wholesalers or through retail networks or distributors.

Aviation Industry - The main stakeholder is Alitalia, Italy’s largest airline company. - ENAV is an Italian company owned by the Ministry of Economy and Finances and

managed by the Ministry of Infrastructure and Transport, through ENAC, the Italian Civil Aviation Authority.

- Another relevant stakeholder is ISAFF (Italian Sustainable Aviation Fuel Forum) - established in June 2013 thanks to the cooperation between ENAC, the Italian Civil Aviation Authority and WEC Italy (the Italian Committee of World Energy Council, a no profit international, multi-energy organization recognized by the UN as global energy body). The Forum is open to Italian energy and aviation stakeholders and aims at including European players as well. Its members include airlines, industry and governmental institutions as well as public and private research organizations. ISAFF acts as a platform for collecting, exchanging and discussing relevant information related to energy and complementary areas in aviation.

Key Projects - Beta Renewables whose key mission is technological innovation, in order to promote

the PROESATM technology for the production of 2ndgeneration biofuels and


biochemicals, with the goal of fast and large-scale deployment of its applications on the market. Moreover, it manages the plant in Crescentino (Vercelli, Italy), the first commercial facility in the world for the production of second-generation ethanol.

- Biochemtex is a global leader in the development and engineering of technologies and bio-chemical processes based on the exclusive use of non-food biomass, as an alternative to oil.

- Thanks to a partnership with Beta Renewables– it realizes technologies and plants to produce bio-ethanol and other chemical intermediates.

- CRB Italian Biomass Research Centre, a new research centre sponsored by the Italian Ministry of Environment and Territory at the University of Perugia. CRB is the Italian reference Centre for research on biofuels and biomass for energy.

- Beta Renewables commercial scale cellulosic ethanol plant at Crescentino (COMETHA (2014-2018), supported by FP7, involves the construction and operation of an integrated industrial facility for the production of second generation bioethanol and other co-products from lignocellulosic feedstock.

- Eni announced plans to convert its Venice refinery into a "green refinery" to produce HVO, using the Ecofining™ process developed with Honeywell-UOP.

4.4.4. Possible voluntary aviation opt-in The aviation opt-in can be implemented in the RED system. A possible implementation could look like the schematic representation in Figure 19.

1. The verification of the sustainability criteria for biofuels and is ensured through a system of traceability throughout the supply-chain this information should be gathered by the registrant.

2. As from January 2012, the economic operators of the production chain of biofuels and bioliquids, whether they are produced in EU and in third countries, who intend to join this system, must be subject to initial and periodic audits by certification bodies accredited by the single certification body, ACCREDIA, through its certification and inspection department.

3. Both the proof of sustainability and the check of ACCREDIA are provided to the GSE. 4. Consequently, the GSE issue the CICs to the registrant/jet fuel supplier. 5. As the jet fuel supplier does not need the CICs, they trade them to the obligated party

on the road fuel side, in return they receive the monetary value of the certificate and therewith cover part of the price premium.

6. The obligated party shows on its turn the CICs at the end of the obligation period to the GSE and therewith fulfils its obligation.


Figure 19. Hypothetical schematic representation of the Italian certificate system including the aviation opt-in

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4.5. RED aviation opt-in member state analysis – United Kingdom9 4.5.1. Obligation for road transport

The RED sets a target that 10% of energy used in transport must come from renewable sources by 2020. A significant proportion of this target is expected to be met through the supply of sustainable biofuels. The UK’s Government seeks to reduce the greenhouse gas emissions from the transport sector as part of its wider aim of addressing climate change. The Renewable Transport Fuel Obligation (RTFO) scheme is a legal instrument that encourages reductions in greenhouse gas emissions in the UK by substituting some of the fossil fuels used in road transport and gas oil used in non-road mobile machinery10. In particular, obligated suppliers are those who supply more than 450,000 litres per year of road transport and non-road mobile machinery fuel. The RTFO came into force on 15 April 2008 and included voluntary sustainability targets. On 15 December 2011 the RTFO was amended in order to transpose the transport elements of the RED into UK legislation. The most significant change was the introduction of mandatory sustainability criteria for biofuels in the UK and the introduction of double counting for biofuels derived from wastes and residues. The current criteria include a requirement for suppliers to show that their biofuels deliver greenhouse gas reductions of 35% against the equivalent fossil fuel, rising to 50% in January 2017. In addition, the cultivation of biofuel feed-stocks should not cause loss of carbon stocks or biodiversity. Biofuels that do not meet the sustainability criteria will be treated as fossil fuel under the scheme. The RTFO scheme was amended from 15 April 2015 to increase the reward for certain renewable gaseous transport fuels, to align the treatment of hydrotreated vegetable oil (HVO) and fatty-acid-methyl-ester (FAME), and to clarify the approach to rounding of RTFCs and fuel volumes. Aviation biofuels currently do not take part in the RTFO system. Therefore, sustainable aviation, founded in 2005 to bring together major UK airlines, airports, manufacturers and air navigation service providers, has been advocating for suppliers of sustainable aviation fuel to have an opt-in option to the RTFO. Moreover, sustainable aviation contributed to the 2015 Transport Energy Task Force last year launched by the UK government which looked at future policy options for transport fuels and will participate in the formal public consultation on future RTFO legislation in summer 2016 launched by the government which will probably include aviation and addressing the issue of ILUC.

9 Work mainly executed by Boeing, aligned with SkyNRG research by SkyNRG 10 In additional to fuels used in road transport, the RTFO covers liquid fuel used in non-road mobile machinery, agricultural

and forestry tractors, inland waterway vessel and recreational craft when not at sea.



4.5.2. Certificate System The RTFO operates on an annual basis starting each year on 15 April. Each supplier of fuel to the UK market11 is required to demonstrate that biofuel has been supplied to cover a set proportion of their overall fuel supply. For the 2014-15 year, this proportion was set at 4.8%. Suppliers can meet this obligation either:

- by redeeming certificates that they have received for their own biofuel supply, or - by redeeming certificates that they have bought from other suppliers of biofuel.

The RTFO operates with tradable certificates. These are called Renewable Transport Fuel Certificates (RTFCs) and are awarded to suppliers of sustainable biofuel. RTFCs are issued by the RTFO Administrator on a monthly cycle and applications for RTFCs received after the cut-off date will be processed the following month. The last possible date for RTFC applications to be received is 14 August. The system of issuing certificates is shown in Figure 20. The system is very comparable to the Italian and Spanish system.

1. The biofuel suppliers must provide evidence that their fuel meets the sustainability requirements.

2. All suppliers (whether obligated or non-obligated) wishing to apply for RTFCs for their biofuels must report independently verified information on the sustainability of their biofuels to the RTFO Administrator; this verification must be carried out by a competent party according to the International Standard on Assurance Engagements (ISAE 3000)

3. Both obligated and non-obligated suppliers who wish to claim RTFCs are required to report all fuel volumes together with the gathered sustainability information to the RTFO.

4. If the sustainability criteria and independent verification are approved the RTFO issues the RTFCs to the obligated party.

5. The obligated party can at the end of the obligation period hand in their certificates and therewith fulfil the obligation.

11 Except those supplying less than 450,000 litres per year.


Figure 20. Schematic overview of the road transport biofuel certificate system in the UK

Sustainability Criteria As regards the sustainability criteria for the obligated parties these entail the RED and FQD sustainability standards. The RED and FQD have set mandatory minimum requirements on the following elements:

- Greenhouse gas (GHG) emissions savings (Article 17(2)): Biofuels must achieve at least a 35% GHG emissions saving, increasing to at least 50% from 1 January 2017.

- NUTS2 (Article 19(3)): For EU crop-based feed-stocks, parties are only allowed to use the RED GHG default values if the feed-stock is from a region where the typical GHG emissions from cultivation of agricultural raw materials can be expected to be lower than or equal to the disaggregated default value for that raw material (set out in Annex V.D of the RED). Regions are defined at the NUTS2 level. Member State reports on emissions from cultivation are published on the European Commission Transparency Platform10. Note that revised NUTS2 codes (NUTS2013) have come into effect from 1 January 2015.

- Biodiversity (Article 17(3)): Biofuels may not be made from raw material obtained from land with high biodiversity value at any point during or since January 2008. The European Union adopted a Regulation on the definition of highly biodiverse grasslands on 8 December 2014, which applies from 1 October 2015.

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- Carbon stock and peatlands (Articles 17(4) and 17(5)): Biofuels may not be made from raw material obtained from land with high carbon stock or land that was undrained peatland in January 2008 unless strict criteria are met.

- Cross compliance (Article 17(6)): Biofuel feed-stocks grown in the European Community must be cultivated according to the European Commission's 'Cross Compliance' requirements (point A and row 9 of the table in Annex II to Council Regulation (EC) No 73/2009 of 19 January 2009) and the minimum requirements for good agricultural and environmental condition (see Article 6 of the same Regulation).

Value Biofuels have historically been more expensive than fossil fuels. Fuel suppliers/retailers are likely to pass much or all of these additional costs onto the final consumer. Biofuels also have lower energy content per litre, so the use of biofuels increases the cost of motoring. The UK Department of Transport estimated the cost imposed by the RTFO using monthly volumes of biofuels as reported through the RTFO statistics. A double-counting system is in place. Under the RED, biofuels derived from wastes, residues, non-food cellulosic material, and ligno-cellulosic material are double counted towards Member States' renewable transport targets and towards suppliers' obligations. This means that one litre of biofuel produced from wastes/residues will receive two RTFCs12. Biofuels from non-food cellulosic and ligno-cellulosic materials such as Miscanthus and woodchips are also double counted. This is to encourage better biofuels that are more sustainable. Biofuels from feed-stocks that are eligible for double counting receive double the number of RTFCs per litre (or kilogram in the case of biogas) as their single counting equivalents. Biofuels from wastes and residues (with the exception of agricultural, aquacultural, fisheries13 and forestry residues) will also be considered to have automatically met the land use criteria required by the RED and FQD. RTFCs may be bought or sold on the open market. RTFCs have a maximum buy-out price of 30p/litre, but currently they are trading at less than this. Any money received from suppliers buying out is distributed between suppliers who have redeemed RTFCs and those who have chosen to surrender additional RTFCs for this purpose.

Trading Certificates Obligated suppliers have multiple options of getting their certificates, as certificates can be traded amongst parties:

- supplying a certain percentage of sustainable renewable transport fuel; - purchasing certificates from other companies supplying renewable fuel; - combination of any of the above.

12 For biogas produced from feed-stocks that are wastes, residues, ligno-cellulosic or non-food cellulosic materials, the number of certificates will be doubled to 3.8 and 3.5 RTFCs per kilogram of biomethane and biobutane or biopropane (or a combination of both biobutane and biopropane) respectively. 13 In many cases materials from aquaculture and fisheries will automatically meet the land based criteria because these materials are not usually sourced from the land. However, suppliers should check with the Administrator which criteria must be demonstrated on a case by case basis.


Moreover, fuel suppliers can meet up to 25% of their obligation with certificates issued in previous year. This reduces the impact of unexpected events and provides some protection against year to year volatility of fuel prices.

4.5.3. Stakeholders Government and Regulations

The Secretary of State for Transport is required by HM Treasury direction, as an imputed tax and spend measure, to prepare an annual report in respect of the RTFO scheme established under the Renewable Transport Fuel Obligations Order 2007 (as amended). Moreover, the Department of Energy and Climate Change DECC and the Department of Transport, Low Carbon Fuels provide support for developing Government policy on low-carbon transport fuels.

Biofuel Industry Feedstock In the early years of the RTFO, there was a high proportion of crop-based feed-stocks. Taking into account the risk of ILUC from these crops, the total GHG savings for these years was low and was even negative during the first year. Since 2011, when an additional incentive for biofuels from waste-based feed-stocks was introduced, approximately half of UK biofuels have been made from waste. These feed-stocks reduce the risk of ILUC and therefore give higher net GHG savings. The figure below shows the main feed-stocks from which the UK's biofuels were made in 2014-15. Waste feed-stocks, which have a reduced risk of undesirable impacts, are shown in bold, and represent 50% of biofuels supplied.

Feed-stocks for UK biofuels in 2014-15 Retrieved from: Renewable Transport Fuel Obligation Annual Report 2014-15, UK Department of Transport, March 2016


The RTFO requires road transport fuel suppliers to blend a certain amount of biofuels into fossil fuels. The most significant biofuels deployed through this mechanism are bioethanol (48%), which is blended into fossil petrol and biodiesel (50%), which is blended into fossil diesel. As to the types of advanced biofuels foreseen, it is important to look at both new feed-stocks and new biofuels technology. The long term need is mainly for advanced biofuels for aviation (biokerosene) and HDV (biodiesel). Biofuel production industry

- Oil&Gas UK, a not-for-profit organisation, established in April 2007, is the leading representative body for the UK offshore oil and gas industry.

- Green Fuels, founded in 2003, manufactures and commissions biodiesel processing equipment to produce high quality biodiesel.

Aviation Industry - British Airways, the national airline. Since its merge with Iberia, it became Europe's

third largest scheduled airline. - BP / DuPont Butamax™ technology. In 2009, BP and DuPont announced the formation

of Kingston Research Ltd and the establishment of a £25 million advanced biofuels research center in Hull for demonstration of biobutanol technology.

- Green Biologics has developed Butafuel™ technology, and is coordinator of the Horizon 2020 project ButaNext (2015 - 2018).

- University of Greenwich, UK, announced it is leading a 4-year €10 million project supported by EC FP7 to develop the microalga Dunaliella as a sustainable raw material that captures carbon dioxide and can grow in some of the world’s harshest environment. The project will build a biorefinery called the 'D-Factory’.

- Sustainable Aviation which was founded in 2005 to bring together major UK airlines, airports, manufacturers and air navigation service providers

4.5.4. Possible voluntary opportunity to include Jet Fuel The system as was shown in Figure 20 can be extended with possible SAF production. When SAF suppliers start to claim certificates under the voluntary aviation opt-in. The system could look like Figure 21. The first part is very similar to the road fuel side.

1. The biofuel suppliers must provide evidence that their fuel meets the sustainability requirements.

2. The supplier wishing to apply for RTFCs for their biofuels must report independently verified information on the sustainability of their biofuels to the RTFO Administrator; this verification must be carried out by a competent party according to the International Standard on Assurance Engagements (ISAE 3000).

3. Both obligated and non-obligated suppliers who wish to claim RTFCs are required to report all fuel volumes together with the gathered sustainability information to the RTFO.

4. If the sustainability criteria and independent verification are approved the RTFO issues the RTFCs to the obligated party.

5. As the SAF supplier does not have to keep the certificates, they can trade them with the road transport fuel obligated parties.


6. The obligated party can on its turn, at the end of the obligation period hand in their certificates and therewith fulfil the obligation.

Figure 21. Hypothetical schematic representation of the United Kingdom’s certificate system including the aviation opt-in

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4.6. RED aviation opt-in member state analysis – Germany WORK IN PROGRESS


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5. Conclusion and Discussion The aim of this report was to give insights into the possibilities of the voluntary aviation opt-in for EU member states. This has resulted in this document which consisted of three integrated parts. The first was the Dutch blueprint, which is created by SkyNRG to show how the Dutch aviation opt-in works and what considerations were taken when implementing the aviation opt-in in the Netherlands. The second part was the EU member state categorization, with this categorization six high potential countries (Spain, Portugal, Ireland, Italy, Germany and the UK) were indicated of being able to implement the aviation opt-in within the existing certificate system. In combination with the upcoming ILUC amendment a big opportunity exists for these member states to include the aviation opt-in, when amending their RED legislation in 2016. This categorization was the start of the final part of this report, in which the six high potential member states were analysed in-depth. The analysis showed the current state of the RED implementation, the relevant stakeholders within the member states and finally a schematic overview of how the aviation opt-in could work in the different member states. While the practical implementation might be time consuming and each member state have its own rules for issuing certificates, it can be concluded that all six member states could implement the aviation opt-in into their existing biofuel certificate system, without major modifications. The conducted research faces some limitations worth discussing. When analysing the 28 member states, ‘having a certificate system’ was the leading criteria in the categorization. This is due to the reason that, at the time of writing it is 2016, there are only four years left under the existing RED legislation, which ends in 2020. Therefore, it was needed to find the member states that could include the aviation opt-in with the least amount of modifications in their legislation. For this purpose, the analysis succeeded. However, the reader should take into account that in the post-2020 legislation the RED legislative framework might, and probably will, change substantially. This could make other member states with e.g. a very strong home demand market and local production much more interesting. This report is therefore, for practical use, especially interesting for member states working on their ILUC amendments in 2016. On the longer term this report could be used as an overview for policy and industry stakeholders of how RED legislation was implemented in the EU. Another interesting point for discussion is that the Netherlands included the voluntary aviation opt-in in 2013. Since that moment no one actually used it to generate biofuel certificates with SAF. Partly, this is due to the fact that production capacity is not available in the Netherlands and therefore SAF can simply not be put on the market. But another reason can be found in regulatory challenges. Although the regulatory frameworks for RED road transport and for the RED aviation opt-in are similar, as was also shown in the examples in this report, the practical implications can be complicated and time consuming. SkyNRG has been working with the NEA for 2.5 years to work out the practical issues of the aviation opt-in. For future member states it is therefore recommended to use the Dutch blueprint as an example. As this might save time on the implementation side and accelerates the choice for the right supply-chain. The large-scale implementation of the voluntary aviation opt-in is also influences by the widely discussed uncertainty of the post-2020 situation. As current RED legislation will cease in 2020,


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the uncertainty for the industry increases day by day. This causes producers of biofuels to be very hesitant in investing in large scale biofuel facilities. Furthermore, the fact that the ILUC amendment limits the use of ‘first generation biofuels’ to 7% pushes the member states for quick solutions to produce ‘advanced biofuels’. Such lists of forbidden feedstocks create even more uncertainty and disturbance in the biofuel markets. The policy makers should therefore aim for very clear post-2020 regulations. These regulations should be based on clear ambitious GHG goals, without listing the ‘good’ and ‘bad’ feedstocks. In combination with a long term tradable system of mandates across the EU, the market can decide with technology feedstock combination will be the optimal solution. A mandate for the aviation sector in the EU is difficult due to the competitive disadvantage this causes compared to the rest of the world. However, the aviation industry should take their responsibility and take an active role in stimulating aviation biofuels. SkyNRG received indications that the European Commission is working towards a target for renewable energy in the aviation sector in the post 2020 legislation. The RED aviation opt-in, as shown in this report, could be a first start to prepare the local EU member state legislation for a larger scale implementation of sustainable aviation fuels in Europe and therewith help the aviation industry to reach future sustainability goals.


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6. References 6.1.1. General references

AEBIOM, (2015). AEBIOM Statistical Report 2015. Retrieved from http://www.aebiom.org/ Department for Transport, (2015). Low Carbon Fuels, GHG reporting scheme in Germany European Biofuels Technology Platform, (2015). Accessed: February 2016 from:

http://biofuelstp.eu/country/austria.html http://biofuelstp.eu/country/belgium.html http://biofuelstp.eu/country/bulgaria.html http://biofuelstp.eu/country/croatia.html http://biofuelstp.eu/country/cyprus.html http://biofuelstp.eu/country/czech-republic.html http://biofuelstp.eu/country/denmark.html http://biofuelstp.eu/country/estonia.html http://biofuelstp.eu/country/finland.html http://biofuelstp.eu/country/france.html http://biofuelstp.eu/country/germany.html http://biofuelstp.eu/country/greece.html http://biofuelstp.eu/country/hungary.html http://biofuelstp.eu/country/ireland.html http://biofuelstp.eu/country/italy.html http://biofuelstp.eu/country/lithuania.html http://biofuelstp.eu/country/luxembourg.html http://biofuelstp.eu/country/malta.html http://biofuelstp.eu/country/poland.html http://biofuelstp.eu/country/portugal.html http://biofuelstp.eu/country/romania.html http://biofuelstp.eu/country/slovakia.html http://biofuelstp.eu/country/slovenia.html http://biofuelstp.eu/country/spain.html http://biofuelstp.eu/country/sweden.html http://biofuelstp.eu/country/netherlands.html http://biofuelstp.eu/country/united_kingdom.html

European Biomass Industry Association, (2013). Comparative analysis of the different legal

frameworks; Identification of barriers and opportunities. European Commission, (2010). National Action Plans of EU member states. Retrieved

February, 2016 from: https://ec.europa.eu/energy/en/topics/renewable-energy/national-action-plans

European Commission, (2013). National progress reports on renewable energy goals pursuant to Article 22 of Directive 2009/28/EC. Retrieved February, 2016 from: https://ec.europa.eu/energy/en/topics/renewable-energy/progress-reports

Eurostat, (2014a). Energy from renewable sources. Retrieved from http://ec.europa.eu/eurostat/web/energy/data/shares

Eurostat, (2014b). Final energy consumption by product. Retrieved February 23, 2016, from http://ec.europa.eu/eurostat/tgm/refreshTableAction.do?tab=table&plugin=1&pcode=ten00095&language=en

Global Agricultural Information Network, (2015). EU-28 Biofuel Mandates in the EU by Member State.

Government Offices of Sweden, (2009). Sweden ’ s first progress report on the development


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of renewable energy pursuant to Article 22 of Directive 2009 / 28 / EC, (December). Hanson, R., & Mendes, D. M., (2011). Portugal Portugal Biofuels Standing Report, 1–13. Jim Lane, (2015). Whats new different and hot in military and aviation biofuels. Retrieved

March, 2016 from http://www.biofuelsdigest.com/bdigest/2015/02/19/whats-new-different-and-hot-in-military-and-aviation-biofuels/

Maabjerg Energy Center, (2016). Maabjerg Energy Center. The Danish Government, (2013). The Danish Climate Policy Plan, (August), 61. Retrieved from

http://www.ens.dk/en/policy/danish-climate-energy-policy The European Parliament and the Council of the European Union, (1998). Directive 98/70/EC.

Official Journal of the European Union, 58–67. The European Parliament and the Council of the European Union,(2009). Renewable Energy

Directive 2009/28/EC. Official Journal of the European Union, 52, 140. Retrieved from http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2009:140:FULL&from=EN

The European Parliament and the Council of the European Union, (2015). Directive 2015/1513 of the European Parliament and of the Council. Official Journal of The European Union

Trennepohl, N., (2013). Renewable energy policy database and support. Retrieved from http://www.res-legal.eu/home/

UFOP, (2014). Information about the conversion of the biofuel promotion from an energy quota to a greenhouse gas quota starting in 2015, 2009.

6.1.2. EU Member State Analysis Spain Interviews Conducted by Maarten van Dijk and Francisco Telles, SkyNRG APA – 18-02-2016 CCE – 18-02-2016 CNMC – 19-02-2016 Geregras – 09-12-2015 MAGRAMA – 19-02-2016 SENASA – 18-02-2016 & 19-02-2016 Websites

- CNMC https://www.cnmc.es/es-es/energ%C3%ADa/hidrocarburosl%C3%ADquidos/biocarburantes.aspx

Portugal Interviews Conducted by Maarten van Dijk, Oskar Meijerink and Francisco Telles, SkyNRG ANA Aeroportos – 12-05-2016 ANI – 10-05-2016 APA – 10-05-2016 DGEG – 11-05-2016 ENMC – 11-05-2016 Galp Energia – 12-05-2016 GPP – 10-05-2016 GPPQ – 10-05-2016 Iberol – 10-05-2016


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LNEG – 11-05-2016 Sovena- 10-05-2016 TAP – 12-05-2016 Websites

- ENMC http://www.enmc.pt/en-GB/activities/biofuels/ - ENMC Ticketing system http://www.enmc.pt/static-img/2015-07/2015-07-

08155548_f7664ca7-3a1a-4b25-9f46-2056eef44c33$$72f445d4-8e31-416a-bd01-d7b980134d0f$$03651d22-7414-4a36-a021-8756545b7719$$File$$pt$$1.pdf

Ireland - Irish Examiner http://www.irishexaminer.com/ireland/turning-the-

tapon-biofuels-193845.html - Irish Government http://www.dcenr.gov.ie/energy/en-ie/Renewable-

Energy/Pages/Biofuels.aspx - NORA http://www.nora.ie/biofuels-obligation-scheme.141.html - NORA BOS system http://www.nora.ie/bos-documentation/procedures-

application-forms.275.html http://www.nora.ie/_fileupload/File/10P1426_BOS_Information_Circular_Nov_2010_27248638.pdf http://www.nora.ie/biofuels-obligation-scheme/administration.142.html

Italy Interview

- David Chiaramonti Professor of Renewable Energy Systems at the University of Florence, Italy. Specialized in Renewable Energies (mainly bioenergy/biofuels, wind and small hydro power) and Innovative Energy Technologies.

Adele Finco (eds.) & Franco Angeli, (2013). Biofuels Economics and Policy. Agricultural and Environmental Sustainability.

Van Grinsven A., Kampman B., (2015). Assessing progress towards implementation of the ILUC directive – Annex F, Italy, CE Delft.

- GSE http://www.gse.it/en/company/Pages/default.aspx - Sustainability Criteria

http://www.assorinnovabili.it/public/sitoaper/FontiRinnovabili/Pubblicazioni/paper%20sostenibilitt_%20Centro%20Studi%20APER-%20REEF_2011_2.pdf

United Kingdom - Government Statistics https://www.gov.uk/government/collections/biofuels-

statistics - Greenfuels UK http://greenfuels.co.uk/ - UK government https://www.gov.uk/government/collections/biofuels-

statistics - University of Greenwich http://www2.gre.ac.uk/about/news/articles/2014/a2816-

algae-research-gives-hope-for-renewable-carbon-negative-source-of-food-and-medicines

http://www.enmc.pt/en-GB/activities/biofuels/

http://www.enmc.pt/static-img/2015-07/2015-07-08155548_f7664ca7-3a1a-4b25-9f46-2056eef44c33$$72f445d4-8e31-416a-bd01-d7b980134d0f$$03651d22-7414-4a36-a021-8756545b7719$$File$$pt$$1.pdf





http://www.irishexaminer.com/ireland/turning-the-tapon-biofuels-193845.html

http://www.irishexaminer.com/ireland/turning-the-tapon-biofuels-193845.html

http://www.dcenr.gov.ie/energy/en-ie/Renewable-Energy/Pages/Biofuels.aspx

http://www.dcenr.gov.ie/energy/en-ie/Renewable-Energy/Pages/Biofuels.aspx

http://www.nora.ie/biofuels-obligation-scheme.141.html

http://www.nora.ie/bos-documentation/procedures-application-forms.275.html

http://www.nora.ie/bos-documentation/procedures-application-forms.275.html

http://www.gse.it/en/company/Pages/default.aspx




https://www.gov.uk/government/collections/biofuels-statistics




http://www2.gre.ac.uk/about/news/articles/2014/a2816-algae-research-gives-hope-for-renewable-carbon-negative-source-of-food-and-medicines



the voluntary red opt-in for aviation biofuels · in could be implemented into the red legislation....

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