Dear VP Timmermans,

We know you want to do the right thing on climate and ecosystem restoration, but you’re scaring us, because your recent statements in an interview at Euractiv suggest that you’re still not clear on certain key principles around forests and biomass energy.  We need policymakers to treat climate change and ecosystem restoration with the seriousness they’d treat national defense or terrorism., so we’ve provided some commentary on your interview below. For context: our position is that the RED should be reformed to exclude primary woody biomass (“forest” biomass) – but that secondary woody biomass (mostly mill residues) can still qualify under the RED as long as material use is prioritized over energy use, in accordance with the principles of the circular economy and the waste hierarchy. We’ve posted proposed legislative language to accomplish these reforms (see memo and RED mark-up).

From the interview:

This massive increase in renewable energy, how much of it actually depends on biomass?

Well, without biomass, we’re not going to make it. We need biomass in the mix, but we need the right biomass in the mix. I hate the images of whole forests being cut down to be put in an incinerator. I think it’s unsustainable and it’s indefensible.

“Without biomass we’re not going to make it” – ? Presumably you mean the renewable energy target, but that target isn’t the one that matters – what matters is the GHG reduction target. To actually reduce emissions, you need to stop counting and subsidizing any form of renewable energy that doesn’t deliver big benefits right away.  Burning forest biomass emits more CO2 at the smokestack or chimney than burning fossil fuels, per unit energy, so right off the bat, something miraculous needs to happen for forest biomass to “reduce” emissions, except on paper. The EC’s scientists have acknowledged that burning forest biomass may not deliver emission reductions compared to fossil fuels for decades to centuries. And, importantly, the most realistic IPCC scenario in the “1.5” report – the one that envisions a liveable future without relying on deployment of fantasy technologies like BECCS – includes a decrease in bioenergy use relative to 2010 levels. See description here.

We agree that logging forests for fuel and treating it as renewable energy is indefensible. However, it’s critical for you to understand that the carbon impact of logging forests is about the same whether it’s one hectare clear-cut for fuel, or two hectares where only half the wood is taken for fuel, and so forth. It’s all forest carbon that’s now in the atmosphere.

But I also believe that, in primal forests, if you maintain them, there’s always a lot of biomass that you can take out – you even help the forest by doing that. Or, in production forests, you never use 100% of a tree. There’s may be close to 20% of the tree that you can’t use for construction or other industries. If you use that in biomass, nothing gets lost.

This is really alarming. We aren’t sure what you mean by “primal” forests, but if you’re referring to “primary” forests – which by definition means forests that are not logged or managed – then are you saying that logging “helps” manage unmanaged forests? We are sure you did not mean to contradict the EU’s own Biodiversity Strategy, which aims for “strict protection of all primary and old growth forests“ in the EU. Please – walk this back. We can’t even imagine the high-fives going on by the biomass industry when they read that!  They’d like nothing better than to help the EU “manage” its last tiny remnants of primary forests.

Can you get some real forest ecologists as close advisors? Logging does not “help” forests. Natural forests did fine for millennia without being logged, and in fact, as the EC’s Joint Research Centre recently stated in their report on biomass, even just removing harvesting residues (tops and limbs left over after logging) is very damaging to ecosystem function, degrading ecosystem carbon and nutrient status as well as damaging biodiversity.  Please see the JRC’s table (short summary, or at report itself) and understand – the majority of biomass removal scenarios are in the medium to high risk categories for biodiversity and ecosystem impacts. Removing biomass does not “help” forests.

Regarding the use of 20% of biomass from production forests, if you are referring to the sawdust, offcuts and bark from sawmills and pulp mills, much of that material can and should be used to make material goods – that’s in line with the principles of the circular economy and the waste hierarchy.  Only if those uses are prioritized should these materials be burned for energy. We need to decrease the rate at which forest carbon is entering the atmosphere.

I know there is a very strong debate and campaigners have made the case to me that biomass is bad by definition. But I don’t agree, there can also be good biomass. That said, you have to have rules in place, and you have to implement and police the rules. That will be our task. If we do all of that correctly, if we use the best available scientific knowledge, the newest technologies, then we can have sustainable use of biomass.

Please don’t misrepresent what scientists and environmental advocates are asking for.  When we met with you we made it clear that the campaign is working to take FOREST biomass out of the Renewable Energy Directive – not ALL biomass.  We’re sure some of your advisors would like to make us sound like the extreme ones, when in fact, it’s EU policy that pays people to cut and burn trees for energy that is radical and extreme.

With regard to using “the best scientific knowledge” and the “newest technologies” to achieve “sustainable use of biomass” – the EU’s sustainability criteria for biomass are not even as rigorous as those of the voluntary scheme of the Sustainable Biomass Partnership, and that scheme has been used to certify the worst forest destruction and clearcutting as “sustainable.”  It’s time for real reform, not just nice words.

Currently, under EU law, biomass is considered carbon neutral by definition. Does that need to be changed?

No, biomass is not considered carbon neutral per se, but the accounting is different. You don’t count the carbon when you burn it, you account for the carbon at production, when it grows. That’s how the LULUCF regulation works.

We’re glad you agree that biomass isn’t carbon neutral, but we’re puzzled why you think using a technology that you admit isn’t carbon neutral is going to help the EU become carbon neutral.  The EC’s own scientists admit that burning forest biomass increases emissions compared to fossil fuels for decades to centuries. How does increasing emissions for decades to centuries help reduce emissions?

Some people argue this needs to be revised because the carbon footprint of biomass can be so different, and that biomass should not even be considered a renewable form of energy.

I disagree. As long as you can account for the footprint elsewhere, which is at the production under LULUCF, I think you can solve the problem. Because it’s different than fossil fuels – you take the biomass from vegetation that has contributed to removing CO2 from the atmosphere. So it’s a different approach. But it’s not carbon neutral. And we’re not pretending it is – we’re only accounting for it differently.

How does counting biomass emissions under the LULUCF rules “solve the problem”?  Member states are giving billions of euro each year to companies that log and burn forests… and counting the emissions in the land sector is going to solve the problem? Even the notoriously conservative JRC has acknowledged a mismatch of biomass incentives and deterrence (see page 10 here).  The question of where emissions is counted is hardly relevant – what’s relevant is, EU POLICY IS SUBSIDIZING LOGGING FORESTS, WHICH UNDERMINES CLIMATE CHANGE MITIGATION.  (This is how we know that you’ve been poorly briefed – because we believe that if you think about this, you will see how nonsensical this justification is).  

Regarding “not pretending” biomass is carbon neutral: EU policies make forest biomass eligible for subsidies the same as wind and solar – so in effect, indeed, you are “pretending” it’s carbon neutral, because if policy actually acknowledged the true carbon impact of burning forest wood, you’d be penalizing people who did it, not rewarding them. Further, biomass CO2 emissions from existing levels of use – plus increases, up to a point – will not be counted under the “forest reference level” approach, which by design (as a baseline) counts all existing use of wood as having zero emissions.  So that’s the current level of harvesting (that you state below is contributing to ecocide) – that’s what’s being counted as the zero-level baseline.  See page 21 of the critique of the Impact Assessment for RED reform for more detail.  Bottom line: EU policy is treating all existing use of biomass not just as zero-emissions in the energy sector, but zero-emissions in the land sector, too – because of the baseline problem.

Because of those issues, the growth potential of biomass is necessarily limited, correct?

Yes, it is, obviously. Let’s be clear: 75% of our forests are in bad shape. We have a huge biodiversity challenge. Ecocide threatens the survivability of our forests. I certainly don’t underestimate the challenge we face, but still, I believe biomass can play a very useful role in the energy transition.

Dear VP Timmermans, we love you for using the word “ecocide” because it’s how we know you’re sincere about wanting to restore ecosystems and save the climate.  We just wish you’d see the connection between forest ecosystem and carbon sink degradation, exploding growth in biomass subsidies, and more 50% of the EU wood harvest now being burned for energy. Business as usual got us to these current levels of logging, and any “solution” that allows logging to continue at the same level, or increase, will make the problem worse. Remember that current levels of logging involve clear-cutting forests so the ecosystem is effectively destroyed.  Each year, logging marches across the landscape obliterating new forest ecosystems that are effectively then lost for any human timescale, and possibly forever. To reverse these trends will require a significant decrease in logging. Unfortunately, so far the options your people have offered are mostly just business as usual that will not produce a meaningful decrease in logging. Only one thing will help restore forests and the carbon sink – stop counting primary woody biomass (“forest” biomass) toward renewable energy targets, and stop allowing Member States to subsidize burning forest wood. It’s simple, and it’s science-based.

How much growth in biomass do you assume for 2030? Because currently, biomass is roughly 60% of our renewable energy and that’s massive. Do you expect that to grow much?

I don’t think that will grow. In proportion to the other renewables, it will probably become smaller, not bigger.

That’s not what the member state National Energy and Climate Plans say! As the leaked impact assessment found, “the majority of Member States foresee an increase in bioenergy use from 2021-2030 and do not detail the sustainability, biodiversity, nor environmental impacts… many of their national plans lack details on how to supply the required sustainable biomass, by feedstock and origin and trajectories for forest biomass, and how they are aligned with measures to maintain and increase the carbon sink.”

Also, please remember that the majority  of forest wood counted toward the EU’s renewable energy targets is burned for residential heating. This is not new capacity; it is not innovative; it pollutes and kills people; and it’s baked into the LULUCF forest reference level baseline, so the CO2 emissions from this use (as well as all other existing uses) will not be counted – nor will they ever be.  See page 21 of the critique of the Impact Assessment for RED reform for an explanation why.  Even the JRC has called for reconsidering the forest reference level approach – and they are practically the ones who invented it (see page 10 here).   

We are really counting on you, VP Timmermans, to enact reforms that put forests and climate first.  Please take it seriously, like you would if this were a matter of nuclear détente or another pandemic. Please get the science right.

An open letter to VP Timmermans concerning statements on biomass policy to Euractiv

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