According to Euractiv, distorted data has been used to determine the impact of the EU Renewable Energy Directive, claims a scientific paper, raising questions about the model and process used by the European Commission to evaluate policy options for decarbonizing transport, including fuels.

A Distorted Market Equilibrium Model

Published in the scientific journal Fuels, the paper examines the so-called Price-Induced Market Equilibrium System (PRIMES) model used by the European Commission to simulate the impact of proposed policies.

The PRIMES model provides a projection of future energy demand and supply, as well as prices and emissions in various scenarios. It was partially used to determine the impact of the Renewable Energy Directive, a key part of EU legislation that contains strict sustainability criteria for biofuel production.

The research, led by Dr. Zoltán Szabó, a sustainability consultant at the biofuel company Ethanol Europe, designed a PRIMES model with revised assumptions using "the most recent market and industry data available."

One of the key differences was the inclusion of co-products in biofuel generation. When ethanol is distilled, protein feed is produced as a byproduct. This is typically used to feed animals, avoiding the need for additional animal feed imports or additional land cultivation.

However, the Commission's calculations did not include the climate impact of having an internal supply of protein-rich animal feed.

Once the new parameters were used, the model produced significantly different results.

While the Commission's modeling found that the cost of carbon reduction for ethanol is in the range of about €220-390/tCO2eq, the revised modeling found that crop-based bioethanol has negative carbon reduction costs.

Electromobility, which was absent from the Commission's impact assessment, was found to be in the range of €100-150/tCO2eq.

The paper concludes that the "transport plans presented [by the European Commission] were not supported by underlying cost assessments," which risks making "EU transport decarbonization efforts excessively costly."

Production of bioethanol in Europe led to higher production of animal feed than fuel in 2021, according to new figures - further evidence that biofuels can also contribute to food security, according to the industry.

Black Box

It is not known exactly how the PRIMES model works - details are not made public, and the model is considered a "black box."

The modeling is carried out for the European Commission by E3Modelling, a private company closely linked to the Technical University of Athens. A request for comment from E3Modelling was not returned.

Energy campaigners have long questioned the Commission's use of PRIMES, criticizing the secretive nature of the model.

Despite the criticism, the Commission maintains its confidence in the PRIMES model as a good analytical tool, emphasizing that modeling is only one element in the development of impact assessments, as the final document is also shaped by contributions from stakeholders' consultations.

It is understood that the data for the PRIMES model is based on the EU 2020 Reference Scenario, an analysis tool that extracts information from national energy and climate plans and consultations with experts.

Joao Pacheco, former Deputy Director-General in the Commission's agriculture department, who is now an adviser to the think tank Farm Europe, said the information presented in the scientific paper questions the validity of Brussels' impact assessments.

"All the wrong assumptions and outdated data put together provide a completely distorted picture of greenhouse gas savings from biofuels and their costs," he said.

"EU policy development is distorted. The EU economy loses, farmers lose, consumers lose, the climate loses," he added.

Pacheco said the Commission's reputation has been tarnished by faulty impact assessments and argued that the Renewable Energy Directive should be reviewed as a priority. "Now is the time to reevaluate what has been proposed," he said.

"Faulty Administration"

Ethanol Europe, meanwhile, presented the Fuel study as a "clear case of faulty administration" by the Commission.

"The PRIMES model has been the backbone of all impact assessments related to the Renewable Energy Directive and policy justifications for 15 years, and all of Europe has had to assume, as the inner workings of the PRIMES model were kept secret, that the model was fit for purpose," said Eric Sievers, director of Ethanol Europe.

"However, we now know that the model and the Renewable Energy Directive are and have always been completely at odds with each other." Sievers described the PRIMES methodology as "unscientific by necessity."