The Brazilian Oil and Gas Institute (IBP) considers it positive that the regulations regarding the new model of the Brazilian downstream are advancing, with the resolutions of the National Energy Policy Council (CNPE), in 09.12, on the new biodiesel commercialization model, the evaluation of the insertion of green diesel in the energy matrix and the guidelines for monitoring the supply of the Brazilian market after the divestment of refineries by Petrobras. Noting that we have not yet had access to the terms of the decisions, we already consider it important to move forward in the discussion and regulation of these issues.

The CNPE resolution that establishes the guidelines for the new biodiesel commercialization model throughout the national territory, replacing public auctions, now promoted by the ANP and with the participation of Petrobras, must be in line with the terms of the Abastece Brasil Report, which has the support of IBP in its broad lines. During the regulation process of the new model, the focus of the IBP will be to show that the authorizing concept of approval of contracts by the ANP, advocated in the Report, does not agree with a model of multiple agents, with freedom of negotiation. There are other mechanisms that would give the Agency the information it needs to monitor the market. The IBP also believes that the release of biodiesel imports could already take place during the transition process, testing the functioning of the market with more than one agent.

The Working Group (GT), coordinated by the Ministry of Mines and Energy (MME) and composed of representatives from different ministries, from ANP, EPE, CADE, will have 120 days to present the final report on the insertion of new renewable fuel alternatives for use in the diesel cycle, in the National Energy Policy. One of the focuses is the regulation of the production of the so-called green diesel, or HVO, and its correct insertion in mandatory mixing mandates and at Renovabio. We reinforce the importance of the WG consulting the society in the analysis process, and for this purpose the IBP is available to build consensus in the final report.

The IBP supports the presence of biofuels in the Brazilian matrix, both for its close connection with agribusiness, one of the most dynamic sectors of the economy, and for its importance for the decarbonization of the economy.

In this sense, we defend the development and use in Brazil of technologies already successfully implemented in other countries in the production of advanced biofuels, such as HVO diesel. The offer of a new product with a renewable basis is in line with society's desires for fuels that emit less, in a sustainable and competitive way, and needs to be properly regulated.

As for the resolution on monitoring national fuel supply in the new downstream scenario, after the divestments from Petrobras, this guarantee is a top priority for IBP. Supply must take place within a strategic and systemic vision that contemplates its complex dynamics and the relationship between the various market agents and society, in terms of price, quality and product offer. However, we still do not have enough information to understand the extent of the CNPE proposal, regarding the scope and instruments for the National Agency of Petroleum, Natural Gas and Biofuels (ANP) to assume the task delegated by CNPE.