The Confederation of European Forest Owners (CEPF) takes note of the Commission´s initiative to review the EU renewable energy rules to contribute to a higher climate ambition as part of the European Green Deal. CEPF supports the target to increase the share of renewable energy in the energy consumption from 32% to 40% by 2030.
However, CEPF wants to raise some concerns regarding the amended sustainability criteria for forest biomass which would hinder the use of biomass for energy and thus prevent reaching the EU goal of ruling out the use of fossil fuels.
Firstly, CEPF calls for stability and predictability in EU policies. The implementation of the latest Renewable Energy Directive (RED II) has just started and the Commission has not yet published guidelines on sustainability criteria which retards the whole process. Possible amendments on this criteria should be considered only after implementing and evaluating the current directive.
The proposed recast of RED II before the full implementation of the Directive in Member States could prevent the achievement of the climate target in 2030 and 2050. Constant changes on the sustainability criteria counteract creating new investments in a sustainable energy production and wood-based innovations.
The Commission´s presumption of ”timber harvest for energy use” stated in the impact assessment needs to be clarified. European forests are not managed for bioenergy purposes but management practices are based on a long-term planning and silvicultural practices performed in a timely manner. CEPF reminds that wood energy market can support EU forest owners to manage their forests – which enhances both the growth of forests and sinks – by providing them an opportunity to get revenues from management operations, and therefore manage their forest instead of leaving them abandoned.
It should be acknowledged that wood bioenergy is largely based on residues and wastes from logging and timber processing and low quality wood. The market ensures that high-quality timber is used for high-value added products.
CEPF is highly concerned about the Commission’s proposal to introduce a delegated act on cascade use of woody biomass. The principle on cascading use is already implemented in practice through the markets of different wood uses. If embedded into EU legislation in a strict way, it would hamper the market functions and the substitution of fossil materials and energy which is in key role in contributing to the climate neutrality target in 2050. In addition, the use of a delegated act for such action is very questionable since Member States should be closely involved in the discussion.
European forest owners also have high concerns about the proposed changes regarding the risk-based approach. The new entries on biodiversity and soil quality introduce new requirements in a rather general way (e.g “degradation of primary forests”, “vulnerable soils” or “large clear cut”) which have not been defined. As a result, it could be very challenging for national forest legislations to comply with these requirements. This new risk-based approach would thus require regulatory changes in Member States and create a large amount of bureaucracy for forest owners who should start reporting sustainability on a forest holding level. In this context, the EU should stick to the risk-based approach decided in RED II in 2018.
Additionally, CEPF does not support the Commission´s initiative to apply no-go areas on highly biodiverse forests given that this terminology is based on undefined terms, leaves too much room to interpretation, does not provide measurable or scientifically based criteria and is too broad to be used in practice in a way that would be relevant for all forest types. If needed, this terminology should be defined and clarified at national, regional and local level. CEPF would also like to remind about the ongoing work on other forest-related definitions under the EU Biodiversity Strategy for 2030 and the need to ensure consistency among the different EU forest-related policies.
EU-wide and undefined terms could risk the availability of wood biomass for energy by excluding several forest holdings performing sustainable forest management and related bioenergy production. These kind of restrictions on forest use would hamper those forest owners who have been managing their land in a sustainable way by preventing them gaining a possible revenue from low quality wood. It could also pose their forests in a high risk in terms of natural disturbances (such as pests, fires and insects) if they are forced to leave all wood material suitable for bioenergy in the forests.
