May, 2021

This is a summary of a comprehensive report on the leaked EC proposal for reforming biomass provisions in the Renewable Energy Directive. See the full report here.

As acknowledged by the European Commission’s own scientists, logging and burning forest wood to generate “renewable energy” in the EU increases net CO2 emissions compared to fossil fuels for decades to centuries, degrades forest ecosystems and biodiversity, and is a significant source of fine particulate pollution, which is estimated to kill nearly 400,000 Europeans per year.

The EU is long past the point when it could meet its biomass needs with mill residues and  other waste wood. Misguided encouragement of burning biomass in the RED has promoted a steep increase in the EU’s dependence on forest biomass and the creation of almost an entirely new wood pellet industry that logs forests for fuel, including in the US, Canada, Estonia, Latvia, Russia, Ukraine, and other countries. In just a few years the international pellet industry went from using leftover sawdust at sawmills to felling whole forests for pellet feedstock, so that now millions of tonnes of trees from natural forests, as well as plantations, are ground up and compressed into wood pellets destined for homes and power plants in the EU.

Recognizing that harvesting and burning forest biomass is damaging forests and the climate, and that the biomass “sustainability” criteria in the Renewable Energy Directive do not provide enough protections, the European Commission (EC) offered options for amending the sustainability criteria in a public consultation, and then discussed the options in an impact assessment (IA), which has now been leaked prior to finalization.[1] Also leaked was the rejection of a version of the IA (not necessarily the leaked version) by the Regulatory Scrutiny Board.[2]

The purpose of this report is to summarize and critique the biomass-related parts of the leaked IA, in particular the options the document offers as potential ways to improve the RED II biomass criteria and reduce the impacts that biomass logging is having on forests and the climate.

Before examining these options, it is necessary to understand how the existing RED II biomass criteria fall short.  The potential revisions discussed in the impact assessment are relevant to particular sections in  Article 29 of the RED II and Articles 3, 4, and 5 of the recently proposed implementing act, which states that biomass plants 20 MW (thermal input basis) or larger will qualify under the RED if they burn biomass for which

  • There are laws on the books in the country where the biomass is sourced that govern legality of harvesting and various principles of forest management (Article 3);
  • However, if those laws don’t exist, then Article 4 applies, which requires that power plant operators provide audited information concerning compliance with paper-thin harvesting guidelines that are mostly optional and have no retroactive enforcement mechanism – the plant having burned the wood, and collected the subsidies, no one will track the fate of the harvested area.
  • Article 5 requires that the source country be a party to the Paris Agreement and have submitted a nationally determined contribution – a box that all major biomass-supplying countries check.

None of the options offered in the IA for amending the sustainability criteria will address the two main problems with forest biomass:

  1. That burning wood for energy emits more carbon pollution than burning fossil fuels per unit energy, and there is no mechanism that can turn this increase in emissions into a significant emission reduction within a timeframe compatible with the EU’s climate mitigation targets of 2030 and 2050..
  2. That harvesting forest wood for fuel – even when it is “forestry residues” – not only instantly converts forest carbon into atmospheric carbon, but profoundly damages ecosystems and biodiversity, even to the point of total destruction, as when mature, complex forest ecosystems are felled for fuel.

Any serious attempt at reform would address these two issues. Unfortunately, the IA is not a serious attempt, as shown by its frequent repetition of the false concept that “sustainably” harvested wood has lower emissions than fossil fuels, a concept that has been roundly debunked by the EC’s own scientists.

The only option that is really going to reverse the climate and ecosystem impacts of 50% of the EU’s forest harvest going up smokestacks is a policy that removes eligibility for forest wood in the RED II.  Excluding forest biomass completely would be an extremely simple and inexpensive solution compared to other approaches that are less effective and more difficult to enforce.

Before the IA’s proposals get any further, they need to be examined and seen for what they are – largely an attempt to ensure that business as usual can continue for the biomass industry.


Option 1: Non-regulatory “new guidance” on implementation of the RED sustainability criteria, thus ensuring biomass use continues at current levels.
: This is a non-option, business as usual, which is clearly unacceptable.

Option 2: Apply the provisions from Article 29(3) of the RED II, which apply to agricultural biomass, to forest biomass. This would put old growth and primary forests off-limits to biomass harvesting. The option also includes making existing power plants (not just new ones) subject to the RED’s GHG criteria, and would slightly increase the efficiency requirement for new power plants only, “in order to protect existing investments.” Nothing prevents biomass use from continuing at current levels or indeed increasing.
: This option would do nothing to reduce biomass use, GHG emissions and air pollution emissions. Burning wood emits CO2 faster than trees can regrow to sequester it, and these modifications do not mitigate that fact. It will not provide additional protection to very much forest area, because a tiny fraction of the EU’s forests are old growth or primary forests. It might help protect some forests in Canada that are being logged by pellet companies in British Columbia, but would probably not protect forests in the US because even 100 year old hardwood forests being harvested for fuel are not considered “old growth.” It would probably not even really protect old-growth and primary forests in the EU meaningfully unless these were put off limits to all harvesting, not just biomass harvesting. For instance, these forests could still be harvested for firewood, and since residential wood-burning is not covered by the sustainability criteria, these changes would not affect this use.  Additionally,

  • Nothing in this proposal changes the fact that burning forest biomass increases emissions compared to fossil fuels for decades to centuries
  • Nothing in this option as written would meaningfully reduce the amount of forest biomass currently used, though the increase in required efficiency level might serve to prevent some additional coal-to-biomass conversions.
  • Yes, primary forests and old-growth forests should be put off limits to all harvesting; this should be the policy no matter what
  • Yes, the GHG criteria should apply to existing plants, it’s impossible to drive change in the industry if this isn’t the case. The criteria should be tightened as well to match the UK’s standard, which is set at a level low enough to exclude wood pellets, due to their relatively high fossil fuel lifecycle emissions. However, none of this will reduce biogenic emissions, which dwarf the fossil fuel emissions related to harvesting, processing and transport that are regulated by the GHG criteria
  • Yes, the facility efficiency criteria should be strengthened and increased, but not by such a small amount. The RED should require a minimum efficiency of 70% as the UK has done, so that only thermal or combined heat and power plants qualify. No electricity-only plant should qualify for the RED, no matter what it’s burning (and this modification would actually reduce biomass use, since large, inefficient plants would no longer qualify).

If the Commission were serious about protecting forests, it would have included  the option of applying the Article 29(4) provisions on agricultural biomass to forest biomass as well, which would exclude areas with “high carbon stock,” including all forested land, and so exclude forest biomass from the RED.  Given how fast we need to reduce emissions, and how slowly forests regrow, there isn’t a big difference between “deforestation” rightly prohibited by the agricultural biomass provisions, and clearcutting forests for woody biomass, which is allowed and even encouraged by the RED’s forest biomass sustainability provisions. Such practices should not be eligible for any support, much less the billions in public subsidies allocated in the EU each year to support burning solid biomass.

Option 3: Applying option 2 to small scale biomass-based heat and power installations below a total rated thermal capacity of 20 MW (e.g.10 or 5 MW). Nothing prevents biomass use from continuing at current levels, or indeed increasing.
: For the above reasons (option 2), this option would do nothing to reduce biomass use, GHG emissions and air pollution emissions, and it would not protect forests in a meaningful way.

Option 4: National caps on the energy use of “industrial quality” stemwood (above a certain diameter size, chosen at member state or EU level), while grandfathering existing volumes in the period 2015-20. Nothing prevents forest biomass use from continuing at current levels or increasing.  Salvage logging would not be included in the cap. The cap would also apply to imports. As with all options under consideration, mill residues would continue to be eligible.

Assessment: This is literally a business-as-usual proposal. By locking in existing volumes of stemwood and presumably allowing demand for “forest residues” and lower-diameter stemwood to continue to grow, this might reduce future use of biomass, or it might simply induce greater harvesting of younger forests with lower diameter trees. Regarding forestry residues, the material greenlighted by option 4, It is important to note that the recent Joint Research Centre report on biomass concludes that while burning some “fine” woody debris (forestry residues, tops and branches) can produce carbon benefits in 10 – 20 years compared to fossil fuels and have a neutral effect on forest ecosystem function as long as enough material is left onsite, burning “coarse woody debris” (generally defined in the scientific literature as material greater than about 7 cm in diameter) is “high risk” for ecosystem function and produces a carbon benefit compared to fossil fuels only in periods over 100 years, or “never.” Likewise, EC scientists concluded in 2016 that burning stemwood would increase net CO2 emissions compared to fossil fuels for “decades to centuries.”

Option 4.1, which fully excludes stemwood and restricts biomass qualifying under the RED to mill residues plus forestry residues, would likely reduce biomass use from current levels, since the JRC report identifies 20% of the total wood in the EU as stemwood. However, since the option would not on its face require a reduction in biomass use, the actual outcome could be to incentivize labelling all forest biomass, even stemwood chipped in the forest, as “residues.”

Option 5: National caps on the energy use from forest biomass based on 2019-2020 values, thus allowing use to continue at current levels. Additional forest bioenergy would not be eligible for subsidies or accountable toward the European/national renewable targets.
Assessment: This has the virtue of recognizing that all forest biomass, not just stemwood, has serious climate and biodiversity impacts, but is still a “business as usual” proposal. As with option 4, while the future expansion of forest biomass use would be capped, the current level of biomass use that would be grandfathered under this option represents about 50% of the wood harvested in the EU today, as well as wood pellets imported to the EU that are made with wood from clearfelled forests in  North America. The entire review of the sustainability criteria and the calls for strengthening the criteria was literally triggered in response to this current level of harvesting that Option 5 proposes to continue.

Regarding ongoing damage from biomass harvesting, the demand for forest biomass can be conceptualized as a kind of stamp that moves across the landscape and cuts out a new section of forests each year. Forests need not be clearcut – the “stamp” can simply result in removal of residues, which was shown by the JRC to have serious ecosystem consquences. Forests take decades to centuries to recover, and some ecosystems are effectively lost forever when they are logged, so critically, this ecosystem loss accumulates even if logging levels remain constant. Thus in summary, since options 4 and 5 grandfather current use of forest biomass:

  • The amount of forest carbon being liquidated into the atmosphere each year would stay the same
  • Air pollution emissions from biomass would stay the same
  • The amount habitat loss and pressure on species would continue to increase each year due to the ”stamp” effect and the slow recovery of forests
  • Current levels of illegal logging to meet current ongoing demand for biomass would stay the same
  • There would be no additional funding reallocated from biomass to cleaner renewable energy technology if bioenergy use and subsidies stayed the same

None of the negative and damaging impacts of carbon pollution, air pollution and forest damage can be reversed unless there is an actual decrease in forest biomass use.  Capping use at current levels would simply be damage limitation.

Other impacts: Burning forest biomass is a high-cost approach, both in a straightforward sense, and with regard to human health.  It is remarkable to see the IA say in the discussion of this option 4 that “Without consideration of air pollution, bioenergy heating is currently one of the cheapest forms of renewable heating.” But air pollution does have a cost – a massive cost to society both economic and in human life and potential. To not model and assess this is irresponsible. The IA’s assessment of economic impacts is extremely crude, but it states that  “wind and solar prices are by now significantly lower than bioelectricity” in the power sector. The relative cost of bioenergy, and comparative benefit of zero-emissions renewable energy, would be even greater if air pollution, forest damage, and climate pollution costs were taken into account.

The model underpinning the EU’s bioenergy projections forecasts a large increase in bioenergy dependence, including for use as BECCS. However, the output of a model is only as good as the data and assumptions that go in to it. These unrealistic forecasts should be deeply alarming to policymakers, because what they actually predict is continued degradation of ecosystems and the EU missing its emission reduction targets. Policymakers should require the models to be re-run using realistic assumptions about how the EU can reach its emission reduction goals.

See the full report here.



The EC offers business-as-usual in their proposal to reform biomass policies
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