UABIO proposals to the draft Law №3356 on the mandatory use of liquid biofuels (biocomponents) in the transport sector. Letter 508
It will be recalled that on April 17, 2020, the Verkhovna Rada of Ukraine registered a draft Law on Amendments to Certain Legislative Acts of Ukraine Concerning the Mandatory Use of Liquid Biofuels (Biocomponents) in the Transport Sector № 3356, which was sent for re-first reading.
In general, UABIO supports the draft Law and considers that confirmation of compliance of liquid biofuels with sustainability criteria is necessary both in view of Ukraine’s compliance with international obligations and in terms of environmental protection.
- Full text of UABIO’s letter № 508 on the mandatory use of liquid biofuels (biocomponents) in the transport sector (in Ukrainian).
However, our team is thoroughly acquainted with the document and has some suggestions for its improvement.
UABIO arguments
- The draft law contains the paragraph: “Technical requirements for reducing greenhouse gas emissions to the production and use of liquid biofuels (biocomponents) and biogas in transport sector are determined in accordance with the national standard.” It should be noted that the introduction of a methodology for calculating the reduction of greenhouse gas emissions and, moreover, the numerical indicators of such reductions at the level of the national standard reduces the importance of compliance with sustainable development.
- Approval of the list of raw materials is necessary in terms of compliance of the text of the draft Law №3356 with Directive (EU) 2009/28 of the European Parliament and Council of 23 April 2009. We need to avoid additional burden on economic operators to collect information.
UABIO proposals
- The numerical value of the reduction of greenhouse gas emissions should be contained in the text of the Law, and the method of calculating such a reduction should be fixed at the level of the Resolution of the Cabinet of Ministers of Ukraine.
- We propose to supplement Article 7-1 of the draft Law with a provision on the need to approve a list of types of raw materials that must meet only the requirements for reducing greenhouse gas emissions.
Proposals are sent to the Chairman of the Verkhovna Rada of Ukraine Committee on Energy, Housing and Utilities Services Andrii Gerus, Deputy Chairman of the Verkhovna Rada of Ukraine Committee on Energy, Housing and Utilities Services Oleh Seminskyi, acting Minister of Energy of Ukraine Yurii Boiko, acting Head of the State Agency for Energy Efficiency of Ukraine Kostiantyn Gura.
The position of the UABIO is prepared, discussed, and agreed upon by the members of the UABIO, which produce more than 50% of all energy from biomass and biogas in Ukraine.
