It is about climate protection in transport. Even though the topic of the "Corona pandemic" is currently dominating the media, we must not lose sight of the topic of "climate protection". We would therefore like to inform not only the political decision-makers but also the public that we are convinced that the European Commission is about to set the wrong course in climate protection in transport, which - regardless of the current temporary greenhouse gas-reducing effects of the Corona pandemic - will lead to a long-term failure to achieve the climate protection goals. 

However, we expressly do not want to denounce the EU Commission, but to enter into a constructive dialogue in order to support the efforts of the EU Commission for the best possible climate protection to the best of our ability. With this important topic, which ultimately affects the whole of society, we are interested in the greatest possible transparency and comprehensibility, so we want to keep the public informed about it. 

In view of the enormous and ever-increasing time pressure, we believe that we can no longer afford any omissions or mistakes in climate protection. Climate protection measures must take effect immediately when implemented. Therefore, we want to stimulate a broad discussion of this topic on a scientific basis and call for a transparent and technology-neutral climate protection policy that is oriented towards real physical greenhouse gas reductions across the entire value chain. In this respect, we see considerable need for improvement in the planned changes to the legal regulations. 

The current regulations still represent an exaggerated one-sided promotion of electromobility. For example, the CO² fleet regulation counts electromobility as having zero CO² emissions, while renewable fuels are not taken into account at all. On the one hand, this is a serious violation of the principle of technology neutrality and prevents a fair competition between different solutions, each measured in terms of the actual greenhouse gas reduction. Secondly, it disregards the laws of nature, because the climate only reacts to real physical greenhouse gas quantities, not to factors arbitrarily set by politicians for the accounting of measures. Moreover, there is a lack of transparency here, as the EU Commission has not disclosed any calculations to the public on what real greenhouse gas reduction can be expected from this measure across the entire value chain including the installation of new infrastructure. On the basis of the scientific studies available to us, we rather come to the conclusion that electromobility in the period up to 2030, which will be decisive for the long-term success or failure of climate protection, will in all likelihood not lead to any significant greenhouse gas reduction over the entire value chain¹, and is therefore ruled out as a medium-term climate protection measure. In particular, the greatly increased CO² emissions from the construction of battery electric vehicles, the high share of fossil fuels in electricity production that will still exist for a long time, the enormous expense of building new infrastructure for charging stations, and the fact that electromobility does not bring any new renewable energy into the system, but rather ties up renewable potential of the electricity sector in the transport sector that is then lacking elsewhere, such as in industry, must be taken into account. 

We see other solutions such as sustainable greenhouse gas reducing alternative fuels (liquid and gaseous fuels including renewable hydrogen, renewable methane and others) which we believe are far more effective because they would be immediately effective in real greenhouse gas reductions in the huge existing vehicle fleet including gas powered cars if implemented and do not require new infrastructure. Legal regulations urgently need to create a level-playing field for these options. Such alternative fuels include not only the biofuels currently on the market, which are predominantly by- products of animal feed production - but also in significant quantities already products from food waste - but also advanced biofuels produced from wastes and residues from agriculture, forestry, the timber industry, the food industry and the like. Furthermore, this includes alternative fuels based on non- biogenic waste materials, such as plastic waste, as well as electricity-based fuels, so-called PtX fuels (Power-to-X) or e-fuels and highly efficient hybrids, i.e. fuels based on both residues or waste and electric power. Pure e-fuels could, for example, be produced in countries with a surplus of renewable energy and imported to Europe. The required carbon dioxide could be captured directly from the air. The technologies for this could well come from Europe which would create more than one million new jobs in Europe according to a current study². By introducing such e-fuels, Europe would have the chance to contribute to covering its very large energy import demand on a renewable energy basis. In addition, this would advance the international cooperation urgently needed for climate protection. After all, climate protection is a global task. 

We have supported our demands with relevant literature and hope to initiate a professional discussion. 

Yours Sincerely, 
Prof. Dr.-Ing. Thomas Willner 
Hamburg, 17 June 2021 

Links:
1 https://www.fvv-net.de/fileadmin/user_upload/medien/pressemitteilungen/FVV_LCA_Life- cycle_analysis_Frontier_Economics_R595_final_2020-06_EN.pdf 
2 https://www.iwkoeln.de/fileadmin/user_upload/Studien/Gutachten/PDF/2021/Gutachten- Synthetische_Kraftstoffe_Europa_englisch.pdf 

Source and Contact
Prof. Dr.-Ing. Thomas Willner
E thomas.willner(at)haw-hamburg.de 

Attachments
Open letter to the European Commission on the risk of failure to meet long-term climate protection goals in the transport sector due to insufficient legal regulations (pdf)

Open letter to the EU Commission on climate protection in the transport sector 169 final.pdf