The Confederation of European Forest Owners (CEPF) welcomes the opportunity to contribute to the Call for Evidence on “Renewable Energy Framework for the decade ahead”.
Bioenergy: a strategic pillar of the energy transition and an enabler of sustainable forest management
Bioenergy is the largest non-fossil energy source in the EU, central to sectors difficult to electrify including heating and certain industrial processes. Forest biomass for energy is a by-product of sustainable forest management (SFM), derived from low-quality wood and residues from harvesting and tending practices. The revenue it generates supports continuous, active and sustainable forest management for millions of private owners, enabling forest health and resilience Through its contribution to bioeconomy, bioenergy supports viable and active SFM ensure forest resilience against fires, pests and storms, and to fight again land abandonment risks.
Strategic autonomy: availability and infrastructure
The recent EU Bioeconomy Strategy mentions that bioenergy sourced from sustainably grown forest biomass and residues is an important part of Europe strategic autonomy. The notion of strategic autonomy does not only stem from the question of availability of a renewable, bio-based resource which Europe has as a domestic, strategic resource. It is also important to underline the nature of the infrastructure around forest-based bioenergy, which is a decentralized one, spreading across the European countryside with a vital role in remote regions. The recent energy crisis and its impact on households and SMEs, must inform the post-2030 framework. The EU cannot have policies restricting the domestic, circular, renewable resources underpinning its energy independence.
Sustainability criteria: implement, simplify, do not reinvent
RED II has not been properly evaluated; RED III is not yet fully implemented. Advancing further sustainability requirements would neither proportionate nor evidence based. In addition, sustainability criteria should continue to apply to biomass used for energy production only, in line with the current framework. Extending their scope would be disproportionate.
Existing legislation, certification schemes and voluntary national practices already provide a robust basis to demonstrate sustainable bioenergy production and already impose extensive reporting burdens on primary producers. The already existing requirements risk having impacts on future biomass supply. The priority must therefore be to simplify, not to add requirements. When promoting locally sourced biomass, equal weight must be given to social and economic objectives, alongside environmental ones, recognising the role of local primary producers and rural economies in delivering homegrown bioenergy and in strengthening EU dependency.
Refinements must respect national legislative competences and avoid undefined parameters burdening small forest holdings. CEPF opposes any legally binding cascading use principle: markets already allocate biomass to its highest-value use, and a regulatory cascade would penalise rural economies.
Sink, storage and substitution
Post-2030 policy must recognise the full contribution of forests to climate change mitigation: sequestration in living forests, storage in long-lived wood products, and substitution of fossil fuels by biomass, including the substitution of fossil used for energy. A sink-only logic distorts investment signals and weakens climate and rural economic outcomes. The millions of jobs in Europe's forest sector depend on a framework keeping forest management economically viable.
Key requests
CEPF calls on the Commission to: evaluate RED II and implement RED III before any new bioenergy related requirements; maintain energy-only scope for sustainability criteria; simplify existing reporting; avoid any legislative cascading principle; recognise and value biomass substitution effects.
The Confederation of European Forest Owners (CEPF) welcomes the opportunity to contribute to the Call for Evidence on “Renewable Energy Framework for the decade ahead”.
Bioenergy: a strategic pillar of the energy transition and an enabler of sustainable forest management
Bioenergy is the largest non-fossil energy source in the EU, central to sectors difficult to electrify including heating and certain industrial processes. Forest biomass for energy is a by-product of sustainable forest management (SFM), derived from low-quality wood and residues from harvesting and tending practices. The revenue it generates supports continuous, active and sustainable forest management for millions of private owners, enabling forest health and resilience Through its contribution to bioeconomy, bioenergy supports viable and active SFM ensure forest resilience against fires, pests and storms, and to fight again land abandonment risks.
Strategic autonomy: availability and infrastructure
The recent EU Bioeconomy Strategy mentions that bioenergy sourced from sustainably grown forest biomass and residues is an important part of Europe strategic autonomy. The notion of strategic autonomy does not only stem from the question of availability of a renewable, bio-based resource which Europe has as a domestic, strategic resource. It is also important to underline the nature of the infrastructure around forest-based bioenergy, which is a decentralized one, spreading across the European countryside with a vital role in remote regions. The recent energy crisis and its impact on households and SMEs, must inform the post-2030 framework. The EU cannot have policies restricting the domestic, circular, renewable resources underpinning its energy independence.
Sustainability criteria: implement, simplify, do not reinvent
RED II has not been properly evaluated; RED III is not yet fully implemented. Advancing further sustainability requirements would neither proportionate nor evidence based. In addition, sustainability criteria should continue to apply to biomass used for energy production only, in line with the current framework. Extending their scope would be disproportionate.
Existing legislation, certification schemes and voluntary national practices already provide a robust basis to demonstrate sustainable bioenergy production and already impose extensive reporting burdens on primary producers. The already existing requirements risk having impacts on future biomass supply. The priority must therefore be to simplify, not to add requirements. When promoting locally sourced biomass, equal weight must be given to social and economic objectives, alongside environmental ones, recognising the role of local primary producers and rural economies in delivering homegrown bioenergy and in strengthening EU dependency.
Refinements must respect national legislative competences and avoid undefined parameters burdening small forest holdings. CEPF opposes any legally binding cascading use principle: markets already allocate biomass to its highest-value use, and a regulatory cascade would penalise rural economies.
Sink, storage and substitution
Post-2030 policy must recognise the full contribution of forests to climate change mitigation: sequestration in living forests, storage in long-lived wood products, and substitution of fossil fuels by biomass, including the substitution of fossil used for energy. A sink-only logic distorts investment signals and weakens climate and rural economic outcomes. The millions of jobs in Europe's forest sector depend on a framework keeping forest management economically viable.
Key requests
CEPF calls on the Commission to: evaluate RED II and implement RED III before any new bioenergy related requirements; maintain energy-only scope for sustainability criteria; simplify existing reporting; avoid any legislative cascading principle; recognise and value biomass substitution effects.
