A newly leaked letter shows that US Representatives are lobbying MEPs to keep the billions in EU renewable energy subsidies flowing to American wood pellet companies.  The letter, written “on behalf of” (and surely written by) US-based Enviva, the largest wood pellet company in the world, contains various misrepresentations.

Four Democrats and 12 Republicans signed the letter. The Republicans are garden variety democracy- and climate skeptics; of the 12, 8 voted to overturn the election of Biden even after the riot at the Capitol on Jan 6, 2021, and they all have generally terrible voting records on environment and climate, with minor exceptions (the table below provides a summary of each Representative’s position). One (Rep. David Rouzer) is infamous for having written a bill compelling North Carolina developers to ignore scientific warnings about climate change and the impact of sea level rise on the coastal shoreline .

It’s sad but not surprising to see Democrats who generally have good environmental records signing on to this letter – almost certain evidence that they don’t really understand that Enviva is logging old growth wetland forests to make pellets and is about as far “environmentally friendly” as it’s possible to get. Two of the four Democrats who signed, Butterfield and Sewell, have received campaign contributions from employees at Enviva (the amounts, respectively $4,000 and $5,000 spread over two election cycles, are typical).

Enviva uses trees logged from wetland forests in the US southeast for wood pellet feedstock (Photo: Dogwood Alliance)

This current lobbying letter should be seen in the context of other lobbying efforts by the US pellet industry to weaken the EU’s proposed reforms on use of forest biomass.

The real question is, are EU politicians swayed by these efforts? The letter, as short as it is, still manages to incorporate several misleading statements, which are critiqued below.

Letter: Thanks to sustainable forest management practices and strong global markets for forest products, our forests in the US have grown steadily, serving as carbon sink and storage, all the while meeting global demand for wood products.

Response: Forests in the US are still rebounding and recovering from radical deforestation that occurred in the 1800s and 1900’s as land was cleared for agriculture. Unfortunately, many natural forests are still being cut down and replaced with monoculture plantations by the forest industry.

Despite claims that forests are growing steadily, in fact they are growing at a decreasing rate. Climate scientists say we must drastically increase forest carbon uptake to avoid catastrophic climate change, but the US forest carbon sink has generally decreased from 1990, when sequestration was -744.5 million tonnes CO2  to 2020, when sequestration was -658.2 million tonnes CO2 (with massive spikes of sequestration loss in the meantime). Overall this is a loss of 11.5%.  If the US forest industry is doing such a great job, why are forests sequestering less carbon now than they did just a few years ago?

US forests sequester less and less CO2. Why does the US forest industry keep claiming they’re doing such a great job?

Letter: We are concerned the Environment (ENVI) Committee’s opinion to the Renewable Energy Directive (RED), currently pending before the Committee on Industry, Research, and Technology (ITRE), may unintentionally undermine trade between the US and EU and negatively impact US forest health. 

Response: Enviva, who clearly wrote this letter, is responsible for logging tens of thousands of hectares of forests each year, including natural wetland forests that are among the most carbon and biodiversity-rich in the country. They tend to build their plants in low-income, majority Black areas that are already burdened with health and environmental problems, then increase air pollution and degrade living conditions for all.  Here is some coverage of these issues from the last couple of years:

Huffington Post

So for them to write about “forest health” is just… sickening. Literally.

Letter: Our specific concern is related to the definition of “primary woody biomass” and its exclusion as a renewable energy source.  We understand that the ENVI sought to prevent high-value wood fiber from being used for biomass.

Response: No, in fact, the ENVI committee voted to exclude primary woody biomass in general (with some exceptions), not “high value wood fiber,” from counting toward renewable energy targets, and from receiving subsidies.

The actual ENVI amendment adopted:

Amendment 8: When developing support schemes for bioenergy, Member States should therefore take into consideration the available sustainable supply of biomass for energy and non-energy uses and the maintenance of the national forest carbon sinks and ecosystems as well as the principles of the circular economy and the biomass cascading use, and implement the waste hierarchy established in Directive 2008/98/EC of the European Parliament and of the Council. For this, they should grant no support to the production of energy from primary woody biomass. In line with the cascading principle, secondary woody biomass should be used according to its highest economic and environmental added value in the following order of priorities: 1) wood-based products, 2) extending their service life, 3) re-use, 4) recycling, 5) bio-energy and 6) disposal. Where no other use for secondary woody biomass is economically viable or environmentally appropriate, energy recovery helps to reduce energy generation from non-renewable sources.

Letter: However, the definition of “primary woody biomass” includes common bioenergy feedstocks, such as tops, branches, damaged or twisted wood, low-value pulpwood, and thinnings—products that are lower-value and cannot be used for long-lived solid wood products.

Yes, “primary woody biomass” is defined in the ENVI amendments as

(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.

So yes, this includes a lot of wood that would not be useful for making into certain products but that is useful – in fact, essential – as carbon storage and wildlife habitat.

Letter: The risk that high-value wood, like saw-logs, from the US will be used for bioenergy is nonexistent and already addressed within the RED through both specific restrictions and sustainability criteria that ensure sustainable harvesting and sourcing practices across the supply area.


There is not a “nonexistent” chance that saw-logs are used as bioenergy feedstock – this does happen and has been confirmed. For example, look at minute 19:55 of the Zembla investigation, where they interview truck drivers delivering wood to an Enviva facility and the driver basically says, “yes, this wood could be used for sawtimber.”  

And there is nothing in the RED II sustainability criteria that restricts wood use to any kind or quality of wood; nor is there anything in those criteria that prevent clearcutting of forests for fuel (see executive summary of the Paper Tiger report).  Nor do the reforms to the RED sustainability criteria (“RED III”)  proposed by the European Commission do much in that regard. That is why we need to simply take forest wood out of the RED altogether as a renewable energy – there is just no way to do forest biomass “well.”

And in any case, the question of what is “high value” wood has no relevance to carbon, biodiversity, and ecosystem concerns. ZERO; NONE.

Letter:  Additionally, the ENVI opinion runs counter to recommendations from the world’s leading scientific bodies who have noted that sustainable bioenergy is necessary for achieving climate goals, including the Intergovernmental Panel on Climate Change (IPCC)1 and the International Energy Agency (IEA)2. We believe the additional restrictions proposed by the ENVI Committee are contrary to our shared goals and will severely reduce the availability of sustainable bioenergy.  


First, weirdly, the IPCC report the letter cites to claim bioenergy is “essential” is from 2011  – this was before the majority of the science had been published about how logging and burning trees increases carbon emissions compared to fossil fuels for decades to centuries. 

For instance, here is what the European Commissions’ own scientists said about burning forest wood in 2016:

However, compared to crops which regrow over short periods, forest biomass is part of a much longer carbon cycle. A forest stand typically takes between decades and a century to reach maturity. Recent studies have found that when greenhouse gas emissions and removals from combustion, decay and plant growth (so-called biogenic emissions from various biological pools) are also taken into account, the use of certain forest biomass feedstocks for energy purposes can lead to substantially reduced or even negative greenhouse gas savings compared to the use of fossil fuels in a given time period (e.g. 20 to 50 years or even up to centuries)

The IPCC obviously recognizes that logging forests is a major source of carbon emissions! Given that, the only way logging and burning forests for fuel can “reduce” GHG emissions compared to fossil fuels is if this actually emitted less carbon – but in fact it emits more carbon.  So given that burning wood emits more CO2 than burning coal, and given that burning wood emits CO2 quickly, while trees take a long time to regrow (if this happens at all), a little basic common sense will tell you that burning wood increases emissions for years… to decades… to even centuries. Along with that, The IPCC’s AR6 Working Group II Report warned that “severe impacts on species [are] likely if bioenergy were a major component of climate change mitigation strategies.”

Letter: At this critical time, we must all work together to address our nations’ closely shared energy and climate priorities.  We urge you to reject the ENVI opinion restricting “primary woody biomass”, which would place the EU’s renewable energy supply at risk and limit the ability of the US and the EU to partner on these important issues.

What hypocrites.

The following table summarizes the positions of the Representatives who signed the letter. An asterisk next to a name indicates that person voted to overturn the election of Biden on January 6, 2021.

RepresentativePartyStatewebsiteVoting record and/or stance on climate and environment issues – representative materialsLink to reference
Earl L. “Buddy” Carter *RepublicanGeorgiaLinkPress release from own website: SCOTUS rejects radical climate agenda, sides with states.  WASHINGTON, D.C. – The Supreme Court today ruled in favor of the states, including Georgia, in West Virginia v. Environmental Protection Agency (EPA), determining that the Obama Administration’s sweeping environmental restrictions violated executive authority. Rep. Earl L. “Buddy” Carter (R-GA) signed a “friend of the court” brief in December advocating for this ruling. “The balance of powers has been restored today,” said Carter. “Republicans since the Obama Administration have been sounding the alarm on the executive branch’s overreaching climate proposals, which sidestep congressional authority while pushing an unsustainable ‘rush-to-green’ agenda. Like Justice Roberts said is his opinion today, moving away from coal is a ‘solution to the crisis of the day,’ but will not meet the demands of tomorrow.”Link
G.K. ButterfieldDemocraticNorth CarolinaLinkLeague of Conservation Voters scorecard – generally goodLink
Bruce WestermanRepublicanArkansasLinkLead sponsor of Trillion Trees Act (tree planting for climate). Ironic!Link
Trent Kelly *RepublicanMississippiLinkLeague of Conservation Voters scorecard – TERRIBLE on everythingLink
Kurt SchraderDemocraticOregonLinkGood on climate but typical western perspective on needing to log forests to save themLink
Terri A. SewellDemocraticAlabamaLinkLCV scorecard very goodLink
David Rouzer *RepublicanNorth CarolinaLinkLCV scorecard terrible (https://scorecard.lcv.org/moc/david-rouzer); also, David Rouzer on Climate Change:
David Rouzer’s record in public office has shown him to be one of the most conservative representatives in Congress, and his stance on climate change is reflected in his political values. According to a 2012 documentary on PBS, during his time in the North Carolina senate, Rouzer wrote a bill compelling North Carolina developers to ignore scientific warnings about climate change and the impact of sea level rise on the coastal shoreline. On the issue, he stated: “Well, you know, I don’t necessarily listen to any one person. And I can’t, you know, tick off a whole list of scientists that are pro-sea level rise and a whole list of scientists that aren’t. I’m just coming at it from a common sense standpoint. The earth has been warming and cooling since day one. And you know, the effect on sea level change, what do we know about it?”. Specifically on the issue of coastal development, Rouzer stated that the climate science of sea level rise is not valid enough to be used towards forming policy, and therefore could have “a negative impact on coastal economies.”
Dan NewhouseRepublicanWashingtonLinkLCV scorecard pretty terribleLink
Tom O’HalleranDemocraticArizonaLink  Great LCV scorecardLink
Eric A. “Rick”’ Crawford *RepublicanArkensasLinkPathetic LCV scorecardLink
Neal P. Dunn *RepublicanFloridaLinkHated the Paris AccordLink
Pete StauberRepublicanMinnesotaLinkVery bad LCV scorecardLink
Jaime Herrera BeutlerRepublicanWashingtonLinkVery bad LCV scorecardLink
Richard Hudson *RepublicanNorth CarolinaLinkWhile a founding member of Conservative Climate Caucus, still very bad LCV scorecardLink
Cliff Bentz *RepublicanOregonLinkAwful LCV scorecardLink
Michael Guest*RepublicanMississippiLinkLoves oil: (Link); Literally has a score of ZERO on LCV scorecardLink

US climate and democracy skeptics want to dominate EU biomass policy

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