The climate risk of allowing feed crops in the EU gas package biomethane target

The European Parliament voted to include a 35 billion cubic meter (bcm) biomethane target in amendments to the Proposal for a Regulation on the Internal Markets for Renewable and Natural Gases and for Hydrogen (recast). In this study, we explain that this target faces potential climate and sustainability risks, particularly with using feed and feed materials to produce biomethane. We explain how policymakers could consider implementing safeguards, specifically by referencing the low-GHG feedstocks in Annex IX of the Renewable Energy Directive.

Based on the findings of this study, we propose the following recommendations:

• Referencing the RED II sustainability criteria alone, and in particular the GHG reduction criteria in Article 29, would not be enough to ensure unsustainable feedstocks are not used to meet a biomethane target in the EU. This is because silage maize, which is associated with significant ILUC emissions, qualifies towards the RED II sustainability criteria.
• Limiting a biomethane target to only those feedstocks in Annex IX in the RED II could ensure only low-GHG biomethane is incentivized in the EU. There is policy precedence for referencing only Annex IX feedstocks in the European Commission’s ReFuelEU aviation regulation. Were intermediate crops to be included in the Annex IX expansion, such a measure could allow biomethane produced from intermediate crops from most, if not all of Europe, to count towards a target, while ensuring maize grown in other regions as a cash crop would be ineligible.
• A target of less than 35 bcm would better align with the amount of biomethane that could feasibly be produced from Annex IX feedstocks in Europe. If subsidies of 1.79 euros were provided per cubic meter of biomethane produced, a target of 14 bcm could be achieved.

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