EU Renewable Energy Directive (RED)

The EU's Renewable Energy Directive (RED) is one of the most important sustainability regulations affecting the production of fuels from renewable resources. It links the binding goal of obtaining 10% of the fuel in the transport sector from renewable resources by 2020 with further sustainability criteria. Among other things these include specifications for raw material cultivation and the CO2 reduction potential.

Necessary harmonization of sustainability standards

International framework conditions are needed to facilitate comparability and thus recognition of the sustainability of a fuel from renewable resources for the aviation sector. This should include ecological as well as economic and social aspects. The recommendations of the Global Bioenergy Partnership (GBEP) initiated by the G8 states or the sustainability criteria catalogues and certification processes of the RSB (Roundtable on Sustainable Biofuels) and the ISCC (International Sustainability & Carbon Certification) and the RSB (Roundtable on Sustainable Biofuels) can serve as examples what an internationally accepted sustainability standard could look like.

In exchange with the mentioned institutions, aireg is examining how this can be achieved internationally. The German Government should take an active role in promoting globally applicable sustainability standards of this kind. In return, the UN Aviation Authority ICAO should make such standards binding. The UN aviation authority ICAO should declare these sustainability standards to be binding.

ISCC sustainability certification system

aireg advocates worldwide sustainability criteria for fuels from renewable resources which cover the entire "life cycle" - from cultivation to consumption. These must be operationalized and reliably verified. Corresponding certification systems already exist, such as the ISCC or REDcert in Germany.

The following overview includes the essential criteria of the current sustainability regulations from aireg's point of view as well as other social and ecological criteria.


Good farming practice,
soil management,
soil protection

Good farming practices are based on the principle of sustainability. They integrate the protection of the soil, water and air within agricultural management and are treated more specifically on the basis of soil management and soil protection. Soil protection includes protecting soil organisms, maintaining a balanced nutrient content and preventing the destruction of the soil structure. All measures to be taken to protect soil are always dependent on the type of soil , climate and topography.
Preservation of above/
below ground carbon
Soil carbon is found in the organic surface horizon in the form of mulch, plants, humus and turf, etc. Areas such as moors and wetlands with a strong organic influence should be protected from change of use due to their climate benefit. In addition to protecting specific areas, this criterion also includes maintaining/improving soil fertility within the cultivated area. This also encompasses additional criteria, such as fertilizer use, erosion, ploughing, removal of residues from the field (straw) etc. In order to protect the carbon content in the soil, some areas must be ruled out for cultivation use.
Use of agrochemicals
The use of agrochemicals – from storage via application through to effects on soils – must meet the previous criteria for the protection of soil and biodiversity. Compliance with local regulations and laws on the use of chemicals is another important factor.
sustainable water use
Includes water management, efficient water usage, conservation and water quality, i.e. measures for planning an environmentally sustainable water supply, identifying and addressing problems as well as monitoring.
AirGHG emissions
The entire value chain must be considered to be able to calculate greenhouse gases, meaning it must undergo a life cycle analysis. Consequently, this criterion is strongly linked with other criteria, in terms of "direct land use change", "indirect land use change" or "site history" for instance.
Air pollution,
no burning for land clearing,
residues burning
Air quality must be secured by preventing/limiting pollution. LCAs can be used to verify this. Local laws and regulations for the burning of waste materials (residues) on land, e.g. in the cultivation of sugar cane, must be observed.
Observing the impact on useable land by cultivating energy crops depending on the previous use of these areas (forest, pastures or wasteland). These observations will also be incorporated in other criteria, including "site history", "biodiversity", "GHG emissions" and "land right issues".
Also necessary to observe: the indirect impact on conservation areas caused by cultivating energy crops on useable land previously used for food crop cultivation. This includes indirect displacement effects which can occur if food production is now moved to previously unused areas. Because there are no EU guidelines for this, it is not yet possible to specifically identify the extent to which this must be considered.
Site history
The site history is essential to ensure that requirements such as these "no go" criteria are fulfilled. The key requirement in this task is to identify an estimated relevant period of time to be considered in the history. This time period can encompass 5-10 years and can be determined, for example, using 1/1/2008, the date appointed in the Biofuel Sustainability Ordinance.
Environmental impact

The assessment of the environmental impact is an important factor in understanding ecological sustainability. As a tool for this purpose, environmental impact assessment of specific projects (e.g. new projects or the plant certification of existing projects).
High conservation value areas,
natural habitats,
high biodiverse land,
endangered species

This criterion can be viewed from two angles. On the one hand, it refers to the management of land already in agricultural use for which, among other things, the criterion of "good farming practices" applies. On the other hand, there is also a focus on areas that according to their history have not yet been used agriculturally and whose conversion must now be considered as a land use change. An HCV assessment (high conservation value assessment) would consider all these perspectives in order to identify "no go" areas, for example.
invasive species

Particularly sensitive flora and fauna must be defined and classified accordingly.
Organisms whose genetic material has been altered by genetic engineering must be defined and labelled as such.


Economic Aspects
Economic performances, energy efficiency, energy balanceThe economic stability of the companies involved must be secured through a resource-saving approach. To this end, energy balances cover the entire production chain.
Economic benefits to communityThis criterion refers to the added value to society, e.g. through employing the local population and boosting local markets. aireg takes the UN Millennium Development Goals as a basis and supports economic and financial development.


Social AspectsSocial Impact
A holistic approach must be taken to viewing social aspects related to the entire value chain. This involves analysing, managing and reviewing the positive and negative consequences.
Consultation of local
The relevant local stakeholders must be integrated in the overall process of the value chain.
Food SecuritySecuring the food supply is the top priority. aireg clearly distances itself from the use of any energy crops, whose cultivation result in competition with local/existing land and water usage.
Social benefits
to community
The prevalent social standards may not be compromised. Possible added social value includes medical care, social institutions and mediating social conflicts.
Human rightsHuman rights serve as the foundation for any action. aireg works on the basis of the UN "Universal Declaration of Human Rights".
Water rightsWater use must not stand in the way of water conservation or deny local populations access to ground water. Official laws on water rights and common law must be observed.
Land right issuesSocial analysis of compliance with land rights by informal and formal contracts that determine rightful ownership or lease arrangements.
Labour ConditionsWorking conditionsGeneral working conditions must be ensured considering the needs of workers. In defining this criterion, aireg works on the basis of the internationally ratified Conventions of the International Labour Organization (ILO).


Operations in compliance with applicable regulations.