Weigh in on EU renewable energy, forests, and climate policies

 

The purpose of this page

The EU is embarking on an ambitious program of new policymaking and revision of existing policies that deal with energy, climate and nature: the EU Green Deal.  See the EC’s own page for timeline and the list of issues covered by the Green Deal.

Very often, the European Commission (EC) provides an opportunity for public input on its proposed measures, including those related to the Green Deal (see current consultations open for comment).  Other EU entities, such as the European Investment Bank, also sometimes open consultations.

The purpose of this page is to help NGO’s and the public comment on EU policies pertaining to forests and climate by highlighting relevant consultations and, where possible, by providing guidance for input that is consistent with forest defender principles.  It also lists some relevant past consultations – clicking on these links takes you to the EC page where all input is listed.

To comment on EC proposals you must set up an account with a username and password, and submit input by midnight on the close-date.  You can paste short comments into a text-box, or upload longer documents.  

If you intend to comment, we recommend that you set up your account ahead of time, and submit comments in a timely way, as the EC website for accepting comments has been known to be Fussy.

Know about a consultation relevant to forests and climate that you think should be listed here? Email us and let us know.

 

Current consultations at the EC

The European Commission consultations are often conducted in stages, with a “roadmap” opened for comment before an actual proposal.  The consultations listed below may be a continuation of process that has already been initiated.

Climate change – restoring sustainable carbon cycles

Carbon removals from forests, agricultural practices or engineered solutions will play a crucial role in achieving climate neutrality by 2050 as they will balance emissions from agriculture, aviation or specific industries that are the most difficult to eliminate.

The initiative aims to support the development of sustainable carbon removal solutions. It will propose an action plan to promote carbon farming and develop a regulatory framework for the certification of carbon removals.

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13066-Climate-change-restoring-sustainable-carbon-cycles_en

Feedback: 09 September 2021 – 07 October 2021  (midnight Brussels time)

 

Current consultations at other institutions

None currently. Let us know if you are aware of any.

 

Past consultations at the EC

European bioeconomy policy: stocktaking and future developments

The Commission will publish this report in response to a request from the Council. The report will assess implementation of the 14 actions under the EU’s 2018 bioeconomy strategy and present preliminary results. It will also explain how the bioeconomy policy is contributing to the objectives under the Green Deal.

Link (scroll down): https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13057-European-bioeconomy-policy-stocktaking-and-future-developments_en

Update: Feedback end date rescheduled from 9 August to 31 August 2021

Feedback: 12 July 2021 – 31 August 2021

 

Sustainable biofuels, bioliquids and biomass fuels – voluntary schemes (implementing rules)

The Commission is taking input on rules to encourage the development of voluntary schemes that set standards for the production of sustainable biofuels, bioliquids and biomass fuels, and to certify that they have been met. This includes standards on reliability, transparency and independent auditing.

Link (scroll down) https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12723-Sustainable-biofuels-bioliquids-and-biomass-fuels-voluntary-schemes-implementing-rules-_en 

Feedback: 29 June 2021 – 27 July 2021

 

Renewable Energy Directive – guidance on the sustainability criteria for forest biomass used in energy production

The EU seeks input on their guidance for implementing the sustainability and LULUCF criteria for forest biomass, aka, “The Emperor’s New Clothes.” See PFPI’s comments here.  

Link (scroll down): https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12943-Renewable-Energy-Directive-guidance-on-the-sustainability-criteria-for-forest-biomass-used-in-energy-production

Feedback: 31 March 2021 – 28 April 2021

 

Forests – new EU strategy

Link (scroll down): https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12674-EU-Forest-Strategy-

Feedback: 25 January 2021 – 19 April 2021

 

Consultation on Protecting biodiversity: nature restoration targets under EU biodiversity strategy and Evaluation of the EU Biodiversity Strategy to 2020

We received the announcement from the European Commission about launching a new online consultation on the development of three inter-connected EU biodiversity policy initiatives, which are relevant for our forests:

  1. The development of legally binding EU nature restoration targets. As a key element of the EU Biodiversity Strategy for 2030 and the European Green Deal, restoring Europe’s damaged ecosystems will help to increase biodiversity, mitigate and adapt to climate change, and prevent and reduce the impacts of natural disasters. The Commission will put forward a proposal for legally binding EU nature restoration targets by the end of 2021. Public and stakeholder views and insights will contribute to the impact assessment.
  2. The evaluation of the EU Biodiversity Strategy to 2020 (2011-2020). The Biodiversity Strategy to 2020 set the EU biodiversity policy framework for the period 2011-2020. This Strategy is currently undergoing an evaluation, looking into its effectiveness, efficiency, coherence with other policies, relevance and EU added value. Lessons learnt from the evaluation of the EU Biodiversity Strategy to 2020 will be considered in the implementation of the EU Biodiversity Strategy for 2030, in order to improve the design and delivery of key actions – including the proposal for binding EU restoration targets.
  3. The review of the application of the EU Regulation on Invasive Alien Species. The EU Regulation on Invasive Alien Species was adopted in implementation of Target 5 of the 2020 Biodiversity Strategy. The review of its application will provide insights for improving its implementation, as well as for the evaluation of Target 5.

The consultation will remain open until 5 April. You can access the joint consultation page from both links below. A separate survey is available on each of the three initiatives. Respondents can choose to answer one or all of the surveys, by selecting the relevant tabs.

Link #1 (scroll down): https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12596-Protecting-biodiversity-nature-restoration-targets

Link #2 (scroll down): https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1832-Evaluation-of-the-EU-Biodiversity-Strategy-to-2020

Feedback period: 11 January 2021 – 05 April 2021 (midnight Brussels time)

 

UK Consultation on Protecting biodiversity: nature restoration targets under EU biodiversity strategy and Evaluation of the EU Biodiversity Strategy to 2020

The UK government Department for Business, Energy & Industrial Strategy and HM Treasury calls for evidence on greenhouse gas removal methods, and comments on policy to deploy those methods. This consultation will impact bioenergy in the EU because the UK is leading on bioenergy carbon capture and storage (BECCS) solutions. Scientists are particularly encouraged to respond to the consultation.

Link: https://www.gov.uk/government/consultations/greenhouse-gas-removals-call-for-evidence

Respond with comment by email to ggr-call-for-evidence@beis.gov.uk

Feedback period: 4 December 2020 – 26 February 2021

 

Consultation/questionnaire: EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12588-EU-Action-Plan-Towards-a-Zero-Pollution-Ambition-for-air-water-and-soil/public-consultation
Feedback: 11 November 2020 – 10 February 2021

Notes: The European Green Deal announced that to protect Europe’s citizens and ecosystems, the EU needs to move towards  a  zero  pollution  ambition,  and better  prevent  and  remedy  pollution  from  air,  water,  soil,  and consumer  products. To  address  these  interlinked  challenges, in  2021 the  Commission  will  adopt  a  Zero Pollution  Action  Plan. Despite important improvements over the last decades, pollution continues to harm citizens and ecosystems. It causes multiple physical and mental diseases, and is one of the five main drivers of biodiversity loss. Pollution comes at a high price for society and ecosystems, including health-related costs (healthcare, lost workdays, lost productivity), reduced yields (e.g.  in agriculture, fisheries  and  tourism), remediation costs (e.g.  water treatment, soil decontamination,  marine depollution)  and loss  of ecosystem services (e.g. pollination).

 

Consultation (questionnaire) EU renewable energy rules – review

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12553-EU-renewable-energy-rules-review/public-consultation
Feedback period: 17 November 2020 – 9 February 2021
Notes: The Commission is preparing a review and a revision of the Renewable Energy Directive to ensure that renewable energy contributes to the achievement of the increased greenhouse gas (GHG) emissions reduction target set in the 2030 Climate Target Plan for 2030. REDII promotes burning forest biomass as carbon zero, renewable solution which we want to stop.

 

Public consultation: Land use, land use change & forestry – review of EU rules

Link (scroll down): https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12657-Land-use-land-use-change-and-forestry-review-of-EU-rules
Feedback: 13 November 2020  – 5 February 2021
Notes: See PFPI comments at http://forestdefenders.eu/hot-ashes-for-trees/

 

Public consultation: National emissions reduction targets (Effort Sharing Regulation) – review based on 2030 climate target plan

Link (scroll down): https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12656-Updating-Member-State-emissions-reduction-targets-Effort-Sharing-Regulation-in-line-with-the-2030-climate-target-plan
Feedback: 13 November 2020  – 5 February 2021

 

Roadmap: Proposal for a directive on Air Quality

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12677-Revision-of-EU-Ambient-Air-Quality-legislation
Feedback: 17 December 2020 – 14 January 2021
Notes: Relevant to use of wood for energy as biomass burning is one of the largest sources of air pollution in the EU.
PFPI comments here

 

Consultation: State aid for environmental protection and energy – revised guidelines

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12616-Revision-of-the-Energy-and-Environmental-Aid-Guidelines-EEAG-
Feedback: 12 November 2020 – 07 January 2021
Notes: To see what’s at stake here, take a look at the submission by the world’s largest pellet company in response to this consultation.

 

Consultation (feedback) 8th Environmental Action Programme (EAP)

Link https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12709-8th-Environment-Action-Programme
Feedback: 05 November 2020 – 31 December 2020 (midnight Brussels time)
Notes: one of the 6 thematic objectives of the 8th EAP is protecting, preserving and restoring biodiversity and enhancing natural capital, notably air, water, soil, and forest, freshwater, wetland and marine ecosystems. We need to ensure that forests receive particular attention as climate mitigation tool through the protection of their carbon stock.

 

Inception impact assessment: Deforestation and forest degradation – reducing the impact of products placed on the EU market

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12137-Minimising-the-risk-of-deforestation-and-forest-degradation-associated-with-products-placed-on-the-EU-market
Type of consultation: Questionaire on proposal for a regulation
Feedback period: 03 September 2020 – 10 December 2020

 

Roadmap Healthy soils – new EU soil strategy

Link https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12634-New-EU-Soil-Strategy-healthy-soil-for-a-healthy-life
Feedback period: 05 November 2020 – 10 December 2020
Relevance: forests contribute to maintaining healthy soils. Soil carbon is an important, but not well studied element of tackling climate change. Protecting forests can help increasing the carbon storage of soils

 

Consultation (questionnaire): Illegal logging – evaluation of EU rules (fitness check)

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/11630-Illegal-logging-evaluation-of-EU-rules-fitness-check-
Feedback period: 03 September 2020 – 26 November 2020

 

Roadmap: Climate change – updating the EU emissions trading system (ETS)

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12660-Updating-the-EU-Emissions-Trading-System
Feedback period ends November 26, 2020
Notes: To ensure the EU is having a neutral impact on climate change by 2050, the Commission proposed raising its 2030 target for greenhouse gas emission reductions to at least 55% of 1990 levels.
The Commission will review all relevant EU policies against this target, including the emissions trading system (ETS), and propose extending the ETS to new sectors of the economy.
It will also review the ETS ‘market stability reserve’ for handling unused emissions allowances after 3 years of its operation.

 

Inception impact assessment: Land use, land use change & forestry – review of EU rules

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12657-Land-use-land-use-change-and-forestry-review-of-EU-rules
Feedback period ends November 26
Notes: See PFPI comments at http://forestdefenders.eu/hot-ashes-for-trees/

 

Roadmap: National emissions reduction targets (Effort Sharing Regulation) – review based on 2030 climate target plan

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12656-Updating-Member-State-emissions-reduction-targets-Effort-Sharing-Regulation-in-line-with-the-2030-climate-target-plan
Feedback period ends November 26

 

Roadmap: Protecting biodiversity: nature restoration targets under EU biodiversity strategy

Link https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12596-Protecting-biodiversity-nature-restoration-targets
Feedback period: 04 November 2020 – 02 December 2020
Notes: Biodiversity, on which we all depend, is disappearing at an unprecedented rate. This initiative is one of the key measures announced in the EU’s 2030 Biodiversity Strategy, which also includes elements for restoring forest habitats (including the planting of 3 billion trees in EU by 2030). It will propose legally binding nature restoration targets, subject to an impact assessment. The initiative will contribute to the goal of the 2030 Biodiversity Strategy: to put Europe’s biodiversity on the path to recovery.
FDA comments here

 

Roadmap: Forests – new EU strategy

Link https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12674-EU-Forest-Strategy-
Feedback period: 30 October 2020 – 04 December 2020
Notes: Under the European Green Deal, the Commission has announced a new EU forest strategy that will build on its biodiversity strategy, cover the whole forest cycle and promote the many services forests provide. The strategy will aim to ensure healthy & resilient forests that contribute to biodiversity, climate goals & secure livelihoods, and that support a circular bioeconomy. It will focus on EU forest protection, restoration & sustainable management, and on world forests where not already covered.
FDA comments here

 

Roadmap: EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12588-EU-Action-Plan-Towards-a-Zero-Pollution-Ambition-for-air-water-and-soil
Feedback period: 01 October 2020 – 29 October 2020
Notes: for those who wish to comment on biomass energy and air pollution, this would be a good one.  There is a bit of information on air pollution contribution of wood-burning at page 20 of the PFPI Paper Tiger report. There is also some good information on air pollution from biomass in the EEB “Burnable Carbon” report (paras 18, 19)

 

Roadmap: European climate law – achieving climate neutrality by 2050

Link: https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2020-119545_en
Deadline: 6 February 2020

Submitted comments: PFPI

 

Roadmap: Illegal logging – evaluation of EU rules (fitness check)

Link: https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2020-581028-0_en

Deadline: February 28 2020
Submitted comments: PFPI

 

Roadmap: Deforestation and forest degradation – reducing the impact of products placed on the EU market

Link: Deforestation and forest degradation – reducing the impact of products placed on the EU market
Deadline: March 4 2020
Submitted comments: PFPI 

 

Draft act: Climate change – standard reporting of action by EU governments

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12158-Structure-format-submission-process-and-review-of-climate-information-reported-under-Energy-Union-Governance
Deadline: March 4 2020
Submitted comments: PFPI

 

Public consultation on draft ETS State aid Guidelines

Link: https://ec.europa.eu/competition/consultations/2020_ets_stateaid_guidelines/index_en.html

Deadline: March 10
Submitted comments: PFPI

 

Roadmap: Industrial emissions – EU rules updated

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12306-EU-rules-on-industrial-emissions-revision

Deadline: April 21 2020

 

Roadmap: EU Green Deal – Revision of the Energy Taxation Directive

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12227-Revision-of-the-Energy-Tax-Directive-
Deadline: April 1 2020

 

Roadmap: 2030 Climate Target Plan

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12265-2030-Climate-Target-Plan
Deadline: April 15 2020
Submitted comments: PFPI

 

Draft act: Renewable Energy Financing mechanism

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12369-Union-renewable-Financing-mechanism
Deadline: June 3 2020
Submitted comments: PFPI

 

Draft act:  Greenhouse gas emissions from land use/forestry – CO2 offsets

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12247-Commission-Delegated-Regulation-amending-Annex-IV-to-the-LULUCF-Regulation
Deadline: September 14 2020
Submitted comments: PFPI, Fern et al, John Spruill, National Wildlife Federation, Swedish Society for Nature Conservation

 

Roadmap: EU renewable energy rules – review

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12553-Revision-of-the-Renewable-Energy-Directive-EU-2018-2001
Deadline: September 21 2020
Submitted comments: European Academies Science Advisory Council (Germany), Tim Searchinger, Wild Europe Initiative (Hungary), National Wildlife Federation (United States), Anonymous (Nova Scotia), bev wigney (Canada), Partnership for Policy Integrity (United States), Biofuelwatch (United Kingdom), Fern (Belgium), Natural Resources Defense Council (NRDC) (United States),  EPN Biomass Network , Southern Environmental Law Center (United States), International Council on Clean Transportation, The John Muir Project (United States), ITPC- International Tree Protection Commission (Italy)

 

Past consultations at other institutions

European Investment Bank’s Climate Roadmap to 2025

Link to consultation: https://www.eib.org/en/about/partners/cso/consultations/item/cb-roadmap-stakeholder-engagement
Deadline: April 24 2020
Submitted comments: see “Stakeholder contributions” at link (large file)

Role of biomass in achieving net zero

The UK Department for Business, Energy & Industrial Strategy seeks to strengthen the government’s evidence base how biomass will contribute to the UK net zero target. Or, how it will not contribute. 

Link: https://www.gov.uk/government/consultations/role-of-biomass-in-achieving-net-zero-call-for-evidence

Feedback: 20 April 2021 – 15 Jun 2021