UFE’s reply to the public consultation on the draft delegated act setting out rules for the production of RFNBO used in transports

UFE welcomes the Commission’s approach to focus on physical properties of electricity and RFNBO production to ensure the renewable nature of the energy produced, as well as the relative flexibility introduced (in relation to the additionality principle and the transitional phase).

UFE recalls its strong support to the general case laid down in RED II, according to which the average share of electricity from renewable sources in the country of production, as measured two years before the year in question, shall be used to determine the share of RFNBO produced.

UFE also makes the following recommendations:

1. Introducing the possibility to extend the transitional phase depending on market developments and the evolution of permitting procedures for renewable assets.
2. Authorising projects receiving State aid in the form of operating aid to benefit from the transitional phase.
3. Clarifying whether the proposed methodologies are cumulative.