If the current review of REDIII is to be successful in ensuring that biomass is sourced and used sustainably, it will be important to have realistic and workable proposals so that operationalisation of requirements can be guaranteed.
Following its commitment to achieve climate neutrality by 2050, the EU is working tirelessly to respond to the climate crisis which the entire world is facing. In this context, the European Council and the European Parliament have reacted with enthusiasm to the European Commission’s proposal to revise the Renewable Energy Directive (REDIII), a fundamental tool for reaching this goal. Today, this revision is all the more relevant because not only does it address the climate crisis, but also needs to reflect the realities facing European energy in the wake of 24 February 2022, when Russia began its war against Ukraine.
Sustainably sourced biomass, and its efficient use in energy applications, are vital for any climate mitigation strategy. By the next decade, the EU must halve its greenhouse gas emissions and slash its fossil fuel dependency. Biomass has an essential role to play in this fundamental transition. Consistent with the IPCC special report of 2018, the Commission's models at the basis of the Fit-for-55 Package include in each scenario an increased utilisation of bioenergy by 2030.
3 Essential Changes Necessary for a Balanced and Successful Framework
With all this in mind, Bioenergy Europe considers that there are 3 fundamental changes that should be made to REDIII to guarantee a successful revision that promotes more renewable energy:
- The definition of primary woody biomass should not be used to determine whether biomass is sustainable or not, since it is not an indicator of quality or specific end-use. The idea that primary woody biomass is not sustainable directly contradicts sections of the 2021 JRC report on the use of woody biomass for energy production in the EU, and is based on a fundamental misunderstanding of how forestry and forest-based industries operate. Therefore, we ask EU policymakers to reject this proposal that would erase 20% of the EU’s renewables in effect overnight.
- The EU should strive to avoid any undue raw material market distortions, which is why cascading should not be regulated at the European level. The Council has recognised the importance of flexibility in its general approach, but the Parliament should go further and avoid a centralised regulation of this issue, because an EU-determined regulation on cascading would not be the right policy tool for preventing such distortions from happening (as recognised in 2018).
- There should be no retroactive application of measures, including vis-à-vis the greenhouse gases (GHG) savings criteria, in order to guarantee legal certainty and maintain business trust in the energy transition. While the Council does make some allowances for old investments, increased regulatory uncertainty will not contribute to greater investment in renewables. The retroactive introduction of GHG savings criteria will lead to the closure of existing plants and the slowing down of, or even the possible reversal of, the energy transition.
4 Important Additional Considerations to Improve the Framework
- The establishment of no-go areas for carbon-rich and highly biodiverse environments can strengthen the biomass sustainability framework only if they can be effectively operationalised. The Council’s inclusion of these areas under the risk-based approach in Article 29(6) is a good way to achieving this. The definitions of these areas should be unambiguous and rely on existing classifications already present at the international level, in agreement with the definitions and mapping used by Member States.
- Forestry is, and should remain, the competence of Member States. EU energy legislation should not "reinvent the wheel" of forestry sustainability. Provisions regulating specifics of sustainable forest management should not be covered by Europe-wide energy legislation, but rather, in accordance with the principle of subsidiarity, be addressed by national, regional and local authorities – including those in third countries. Minimising biodiversity and soil quality impacts are key objectives, but requirements must work for all various forest types, irrespective of where in the world the biomass originates. For this reason, definitions should be based on existing and widely accepted guidelines that can be locally applied. The tools for achieving them should be detailed at the national, regional or local level to ensure the effectiveness and appropriateness of policy actions.
- The exemption threshold for biomass should not be excessively lowered. Although a threshold lower than 20 MW would certify the sustainability of a larger portion of biomass, it would place regulatory burdens and disproportionate cost compliance upon the smallest actors who have little administrative capacity. The Council proposes to lower it to 10 MW and the Parliament to 7,5 MW, but both should consider that time and digitalisation will be necessary before cost compliance can be brought down. To increase our ambition while guaranteeing a workable framework, especially for SMEs and local authorities, we recommend lowering the threshold to 10 MW while keeping a simplified procedure for plants with 10-20 MW.
- Support for installations producing electricity-only from forest biomass should be maintained until 2030. The Council’s step in ensuring market stability by allowing the continuation of existing support, and the Parliament’s provisions to allow existing plants to continue in operation even if the modifications for cogeneration are not possible due to the absence of infrastructure or demand, are positive steps forward. In addition to providing support to Just Transition territories, to installations with BECCS, and in situations where there is no commercial demand for heating, support schemes should be able to sustain biomass power-only generation where it is necessary for the security of the energy supply, the stability of the grid, to prevent re-carbonisation or where a plant can demonstrate it is a feasible candidate for becoming a BECCS project.