A short summary of the RED’s biomass provisions going into the Plenary, July 13, 2022
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Following the ITRE vote today, there is now a final report on the biomass provisions in the RED that will go to plenary in September. The text will represent a combination of amendments voted in the ITRE committee today and previously voted ENVI amendments to Article 29, which are automatically included. (See overview of the Council’s version separately).
- There have been some welcome steps that would reduce or even end MS subsidies and incentives for burning forest biomass, but the impact of these measures will be severely weakened by the loopholes in the definition of primary woody biomass and various other exemptions.
- In reality, taking account of the loopholes in the Commission proposal and the ITRE report, the large majority of forest biomass burned will still be subsidised and incentivised by the RED and counted as zero carbon in legislation such as the ETS.
The gap between what the science shows is needed to save forests and the climate, and what is on the table, is still too wide.
Key amendments proposed by ITRE and ENVI
Counting forest biomass toward renewable energy targets, and subsidizing it
Regarding counting forest biomass toward renewable energy targets, and subsidizing its use, the report contains contradictory provisions.
- The ITRE report leaves unchanged the weak Commission proposal to stop subsidies for burning certain types of forest wood (veneer & saw logs, stumps & roots). This would only apply to a small proportion of wood currently being burned as these types of wood are seldom burned, leaving the big majority of wood still eligible for subsidies
- However the ENVI text (Art. 29) stops subsidies and incentives for using ‘primary woody biomass’ (PWB). This means some PWB would no longer qualify for MS subsidies or count towards national renewable energy targets. This measure is however severely weakened by a loose definition of PWB and several big exemptions:
Weak definition of primary woody biomass
Primary woody biomass (PWB), meaning biomass sourced directly from forests, represents roughly half of all wood burned for energy in the EU. The proposed definition for primary woody biomass (PWB), meaning biomass sourced directly from forests, while a welcome step, is weakened by exemptions for forests affected by fires, pests and disease. This not only continues to incentivize harmful logging but also incentivizes the least efficient and most polluting use of wood, burning it for energy. These are wide-reaching and significant loopholes to allow continued support for burning PWB meaning that under the ENVI proposal, significantly less than half of wood burned will be removed from support schemes. We are particularly concerned about the major loopholes that the fire exemption and disease/pest exemption provide, which allows healthy trees that are pre-emptively logged “to prevent spread” of pests and diseases to qualify as renewable under the RED.
Electricity-only biomass power plants are extremely inefficient. The Commission has proposed ending support for some of these plants, with exemptions. ITRE allowed the exemptions to remain so that plants in Just Transition regions would continue to receive support, and plants that use or plan to use carbon capture and storage (CCS) with biomass to capture carbon (BECCS). ITRE has thus rejected ENVI’s proposal to limit these exemptions to installations of less than 20MW. Overall, while ending support and subsidies for electricity-only plants is an important step, it will affect a relatively small fraction of the wood logged and burned in the EU for energy, even without the exemptions.
Importantly, however, ITRE has added an even larger loophole allowing continued support to any electricity-only plant that cannot easily convert to cogeneration. This thoroughly guts the proposal to end subsidies for these extremely inefficient plants, since in practice this could cover almost all existing electricity-only facilities. Thus again, ITRE is supporting business as usual for ongoing subsidies and incentives for this wasteful, polluting and expensive means of electricity generation.
The cascading principle for forest biomass has been accepted in the final ITRE report, which is welcome. It is however in the form of a weaker ‘implementing act’ by Commission, instead of the ‘delegated act’ proposed by the Commission.
Sustainability criteria and forest protection measures (Art 29)
New protections for forests that were proposed by the Commission were further strengthened by the ENVI text to establish more protection for old-growth forests, peatlands and heathlands by disqualifying forest biomass harvested from those ecosystems from qualifying under the RED. However other changes have weakened the criteria to allow Member States to decide on their implementation. These changes will be confirmed or adjusted at the plenary vote.
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 (26a) ‘primary woody biomass’ means all roundwood felled or otherwise harvested and removed. It comprises all wood obtained from removals, i.e., the quantities removed from forests, including wood recovered due to natural mortality and from felling and logging. It includes all wood removed with or without bark, including wood removed in its round form, or split, roughly squared or in other form, e.g., branches, roots, stumps and burls (where these are harvested) and wood that is roughly shaped or pointed. This does not include woody biomass obtained from sustainable wildfire prevention measures in high-risk fire prone areas and woody biomass extracted from forests affected by active pests or diseases to prevent their spread, whilst minimising wood extraction and protecting biodiversity, resulting in more diverse and resilient forests, and shall be based on guidelines from the Commission.
 See map at https://ec.europa.eu/regional_policy/en/funding/jtf/just-transition-platform/
 Wood should first be used for longer lived products, and only if there are no options for this use should it be burned for energy. https://forestdefenders.eu/wp-content/uploads/2022/06/Why-we-need-the-cascading-principle-for-biomass.pdf