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Comments to Annex IX 2nd feedstock consultation

Svebio, the Swedish Bioenergy Association, does not support the general approach in the regulation in RED with double-counting and definition of “advanced biofuels” as fuels based on certain feedstocks.

In our view, advanced biofuels are biofuels with very high GHG savings compared to fossil fuels regardless of feedstock. We also favor continued and increased use of biofuels from agricultural energy crops, in order to use the abundant resources in European farming (abandoned and fallow farmland, freed acreage as a result of higher yields, increased yields due to rotation crops on currently used farmland, etc). And above all we favor a free market, as this is the basis of the EU. We are convinced that administratively set feedstock regulations and double-counting will distort the markets, create a suboptimal use of raw materials, and lead to unnecessarily higher costs for the energy transition in the transport sector. These regulations also create political risks for companies and investors, and open up for increased lobbying and corruption, as well as for fraud.

The policies should instead be based on carbon pricing and well-designed sustainability criteria. Based on these incentives, both energy efficiency and renewable fuels can compete in a fair way, resulting in the lowest total cost for society and the consumers.

Despite this, we would like to comment on some of the feedstocks.

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