WWF Japan
3F 1-4-28 Mita
Minatoku TokyoJapan
TEL：+81-03-3769-1711
FAX：+81-03-3769-1717
https://www.wwf.or.jp

WWF European Policy Office
123 rue du Commerce
1000 Brussels
Belgium
TEL: +32 494 762 763
FAX: +
https://www.wwf.eu

July 15, 2020

Hiroshi Kajiyama, Minister of Economy, Trade and Industry
New and Renewable Energy Division, Energy Conservation and Renewable Energy Department,
Agency for Natural Resources and Energy

Request for Formulation of GHG Emission Reduction
Standards and Sustainability Standards in FiT Act

In light of concerns over sustainability and, in particular, the potential increase in the emission ofgreenhouse gases (GHG), WWF Japan and WWF European Policy Office urgently request that theobjectives of the Act on Special Measures Concerning Procurement of Electricity from Renewable
Energy Sources by Electricity Utilities (hereinafter, the “Feed-in Tariffs [FiT] Act) be revised toensure that Japan’s support for bioenergy lead to reductions in GHG emissions and avoid repeating
the serious mistakes that have been made in the EU and elsewhere in recent years - and that are nowin the process of being reversed. Increased harvesting of forests or crops for energy will typicallyincrease emissions compared to fossil fuels and runs directly counter to the protection andrestoration of forests and other ecosystems that is required to stop runaway climate change. Withrevised objectives in place, the FiT Act should then be equipped with the sustainability standards toensure that the objectives are achieved.
Currently the FiT Act’s objectives put the focus on the stable supply of energy and therevitalization of local economies. It gives less emphasis to reductions in GHG emissions, whichshould have been the objective in the first place. The FiT Act, which was established to encourage
the use of renewable energy sources such as solar power and wind power, launched the feed-in tariff
scheme for renewable energy from July 1, 2012. The scheme is funded by the fees that citizens arecharged to “promote renewable energy generation.”

WWF Japan released its “2017 Long-term Scenario for the Creation of a Decarbonized Society” inFebruary 2017, which aims to have all of Japan’s energy come from renewable energy by 2050, andour activities have reflected this goal. However, in aiming for 100% renewable energy, in recentyears we have become very concerned that there are no regulations on the reduction of GHG
emissions required of biomass or on ensuring the broader ecological sustainability of feedstocks
used in biomass power generation. Accordingly, in May 2019 WWF Japan released its Position
Paper on the sustainability of bioenergy.
WWF Japan’s 2017 Long-term Scenario for the Creation of a Decarbonized Society(Executive Summary)https://www.wwf.or.jp/activities/data/170413ExusecutiveSummary_ENG_Final_rev2.pdf

WWF Japan Position Paper “Bioenergy as a Sustainable Energy Source” (May 2019Edition)
https://www.wwf.or.jp/activities/data/WWFJapanBiomassPositionENrevMay192020.pdf

Making renewable energy the main source of energy should be predicated on a reduction in GHG.
The Fifth Basic Energy Plan lays out the direction for making renewable energy the main energy
source by 2030. Japan’s energy policy pursues “3E+S,” which is the abbreviation for “energysecurity” (the stable supply of energy, including renewable energy), “economic efficiency,”“environment” and “safety.” Given the need to make substantial reductions in GHG as part of theimplementation of the Paris Climate Agreement, it is important that the effectiveness of Japan’s
biomass power generation in reducing GHG be a priority and expressed quantitatively.

At the very

least, it is essential that a standard be set for the reduction rate relative to fossil fuels. As Japanpursues the broader use of renewable energy, bioenergy feedstocks should only be chosen or
supported by the government on the basis that they will result in GHG reductions compared to fossil
fuels. However in the absence of appropriate sustainability standards, the imported feedstocks thatare introduced under FiT (palm oil and woody biomass, among others) risk increasing GHG
emissions compared to fossil fuels.

In light of the above, WWF Japan and WWF European Policy Office make the following requestsof Hiroshi Kajiyama, the Minister of Economy, Trade and Industry, and the New and Renewable
Energy Division, which is part of the Energy Conservation and Renewable Energy Department inthe Agency for Natural Resources and Energy.

Requests of Hiroshi Kajiyama, Minister of Economy, Trade and Industry
1. Revise the objectives of the FiT Act to ensure that bioenergy subsidies financed by taxpayersdeliver significant reductions in GHG emissions compared to fossil fuels, and establish adequate
sustainability standards accordingly.
2. Instruct the New and Renewable Energy Division of the Energy Conservation and Renewable
Energy Department in the Agency for Natural Resources and Energy to promptly consider andset GHG reduction standards, which should exclude bioenergy feedstocks such as palm oil andother dedicated crops or tree trunks and stumps that will typically increase emissions compared
to fossil fuels and only incentivize fast-decaying wastes and residues with no other uses.

Requests for the New and Renewable Energy Division, Energy Conservation and Renewable
Energy Department, Agency for Natural Resources and Energy
1. Consider and set sustainability standards including GHG reduction standards that areappropriate to the FiT scheme for bioenergy fuels. While only fast-decaying wastes and residues
with no other uses should be incentivized, the discussions of the April 2020 revised edition of
the Guidelines for Establishing Business Plans (Biomass Power Generation) revolve around theways to use a variety of biomass sources for energy. Careful consideration should be given to
the climate impact of burning all potential sources.
2. Establish methods to quantitatively calculate (existing methods would be possible) lifecycle
GHG emissions compared to fossil fuels by a third party that has international credibility andrequire that this method be used across the board. When calculating GHG, the full lifecycle,
from changes in land use, forgone sequestration and indirect land use change to changes inforest and soil carbon stocks and the emissions from fuel combustion, should all be included.

Since this is an open letter, we will release this request to the press. If you may have any questions,please contact WWF Japan.

For a Living Planet
Yours Sincerely,

Sadayosi Tobai,

Ester Asin,CEO, WWF Japan

Director, WWF European Policy OfficeList of Signatories as of July 14, 2020:
Haruki Tsuchiya, Ph. D, Research Institute for Systems Technology
Kenichi Oshima, Ph. D, Professor, Faculty of Policy Studies, Ryukoku University
Biomass Industrial Society Network(BIN)

https://www.npobin.net/

Borneo Conservation Trust Japan http://www.bctj.jp/
FoE Japan https://www.foejapan.org/
Global Environmental Forumhttps://www.gef.or.jp/

Greenpeace Japan https://www.greenpeace.org/japan/
Green Purchasing Network https://www.gpn.jp/
HUTAN Group https://hutangroup.org/
Japan Tropical Forest Action Network

http://www.jatan.org/

Mighty Earth http://www.mightyearth.org/
Natural Resources Defense Council https://www.nrdc.org/
Partnership For Policy Integrity https://www.pfpi.net/
Stand.earth https://www.stand.earth/
General incorporated association Tokushima Regional Energy http://www.tene.jp/