Intermediate crops are set to be considered an advanced feedstock for the production of sustainable aviation fuel (SAF) in Germany, according to the environment and climate ministry's draft bill to amend the Federal Immission Control Act, which aims to implement the EU's renewable energy directive (RED III) into national law.
Cover, or intermediate, crops — defined by the European Commission as crops that are grown on areas where only one food or feed crop harvest takes place, require no additional land use, and maintain soil's organic matter content — are to be considered advanced feedstocks for the production of SAF, in accordance with RED III's Annex IX Part A. This means that SAF derived from cover crops will contribute to Germany's minimum advanced biofuels sub-quota, which is proposed to rise to 3pc by 2030, up from the current 2.6pc goal, under draft legislation.
Germany's draft implementation proposes an end to double-counting of advanced feedstocks, which could increase demand for products including cover crops.
But for non-SAF biofuel production, per Annex IX Part B, cover crops would be considered a non-advanced feedstock. Under Germany's draft legislation, this would be classed as a waste-based feedstock, and would face a cap on volumes that can count towards the mandate, revised up to 2.8pc by 2039, from the current 1.9pc.
Although these feedstocks would be single-counted towards the country's greenhouse gas (GHG) reduction quota, the draft amendments stating that biofuels produced from these materials are "considered to be twice their energy content" in the calculation of RED III targets a share of renewable energy within the final consumption of energy in the transport sector of at least 29pc by 2030.
