Wijziging Regeling energie vervoer

Reactie

Vraag1

- Circtec is preparing a €200 million investment in the Netherlands in a production plant to produce a new marine renewable fuel from Annex IX A waste feedstock (marine-specific renewable fuel that cannot be refined into road transport fuels).
- This proposal is driven by an aim to rebalance biodiesel (FAME and HVO) from marine markets into road fuel markets. This is an understandable motivation. But the proposal does not make a distinction between biodiesel and other renewable fuel types such as Annex IX A advanced biofuels or RFNBOs.
- These emerging marine 'future fuels' cannot switch into the road transport sector, as they are marine specific and cannot be produced as road fuels. The policy assumes all marine renewables fuels can switch between marine and road markets as biodiesel can. This is not the case for many new fuels technologies that are being developed and scaled-up now.
- The impact of the proposal is to directly reduce support (once again) for companies developing future fuels processes. The negative impact is further amplified because future fuels processes are costly to develop and are not in the same economic position as producers of biodiesel.
- Circtec, requests that the policy position in the Netherlands remains stable for developers of these future fuels, until the implementation of the new EU system support system (i.e. FuelEU Maritime). Policy that is aimed at the effects of biodiesel supply into the marine market should be specifically targeted at biodiesel.
- Stable and consistent policy support is needed to make the Netherlands a stable environment for the massive capital investments that will be needed to achieve the Energy Transition. Constant policy change undermines this stable investment environment, which has already been substantially damaged by the impacts of the 'PAS Crisis' on permitting new plants in the renewables sector.
- Without stability and support to scale-up new fuels production technologies the Netherlands faces a disproportionate dependence on oleofuels in the face of widespread and deep mandates that cannot be met with oleofuels alone.
- It is important that the baby is not thrown out with the bathwater every time that flows of biodiesel into the marine sector cause complications for the Netherlands road transport policy.
- We ask that the proposed policy is adjusted and made more targeted, so that it does not negatively impact the development of Annex IXA advanced biofuels and RFNBOs.