Please do not consider forest biomass as an energy source included in the European Renewable Energy Targets.

(see the original letter in Polish here)

Dear Commissioner Wojciechowski,

I represent the Polish Chamber of Commerce for the Wood Industry, the largest organization in the wood industry in Poland. I am also writing to you on behalf of the Association of Producers of Wood-Based Boards in Poland, the Polish Sawmill Industry Association, and the Polish National EPAL Committee expressing our concerns about the revision of the EU Directive on Renewable Energy (RED). The inclusion of forest biomass in the Directive does not guarantee climate neutrality or the protection of biodiversity and therefore undermines the EU’s “do no harm” principle.

Moreover, the current approach and strong support for forest biomass are leading to market distortions with negative effects on other, traditional and more sustainable ways of wood use. Almost 7 billion euro is spent annually on subsidies for forest biomass. Therefore, we urge you to withdraw forest biomass from the EU’s renewable energy targets and to stop supporting it. The wood used in construction and other wood products binds the carbon for a long time while burning it releases carbon into the atmosphere immediately.

The wood industry gives jobs to 330 thousand people in Poland, especially in rural areas. We are convinced that many of our colleagues in other EU countries, representing 1,872,000 jobs, are not aware of the planned RED revision and the threats to their livelihoods that would be provided by further support for forest biomass.

We support, in line with the assumptions of the Commission itself, the cascading use of wood following the principles of sustainable waste management and the circular economy. We urge the Commission to guarantee fair access to raw materials by eliminating market distortions resulting from the subsidies for wood biomass.

The JRC report from January 2021 shows that only one of the 24 forest biomass energy pathways is more climate-friendly compared to the fossil fuel-based system and poses only a low risk to biodiversity over a period that affects EU climate goals. This is pathway nr 5: burning “fine woody debris” (twigs and branches with a very small diameter, bark) ensuring that enough wood is left on-site to maintain the levels of soil carbon, soil fertility, etc. All other 23 pathways either do not lead to any reduction in carbon dioxide emissions in a time shorter than two decades, either pose a threat to biodiversity, or both. Neither the LULUCF regulation, nor the RED sustainability criteria, nor the proposed implementing act restricts the sources of supply of raw materials to those in line with the aforementioned pathway. Importantly, the report did not even assess the scenario where additional trees are felled for energy, which would further deteriorate the competitiveness of our industry.

Another problem is the often-repeated claim that biomass use will not increase to a great extent. In this context, the study carried out by Ember may be of interest. The study shows that the use of woody biomass (mainly in the form of pellets or wood chips) already planned in the EU corresponds to around 5 new Drax projects (Drax is the largest wood pellet consumer in Europe).

Proposed EU projects to switch from coal to biomass could increase biomass consumption by 607 petajoules (PJ) per year. As a result, the amount of biomass burned in existing coal-fired power plants could triple compared to the current level. An additional 36 million tonnes of wood pellets would have to be produced, which is equivalent to the current global production of wood pellets. However, if these projects were to be implemented, only 64 TWh of electricity would be produced, which is less than 2% of the EU’s electricity production. By comparison, the same amount of wind and solar installed capacity increases each year in Europe. The EU’s renewable energy target can be achieved without using forest biomass, which only accounts for around 18% of the renewable energy target.

Moreover, we are concerned about the growing pressure on valuable forests in our country, including those located in Natura 2000 sites, by timber extraction. We believe that the promotion of forest biomass energy in the EU would further increase this pressure. If the wood was not used as fuel, its available quantity would satisfy the needs of the timber industry and on the one hand, some valuable stands could be excluded from forest management, in line with the assumptions of the EU Biodiversity Strategy.

Yours faithfully,

Marek Kubiak – Polish Chamber of Commerce for the Wood Industry

Stop burning forest wood for renewable energy, says Polish Chamber of Commerce for the Wood Industry

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