Forests sacrificed for EU climate policy

14 July 2021

Forests sacrificed for EU climate policy

Today, the European Commission released its revised 2030 climate and energy package. Despite overwhelming scientific evidence that burning forest biomass accelerates climate change and destroys biodiversity, the Commission ignored its own scientific advisers and proposed to keep incentivising the destruction of forests through its renewable energy policy. While the Commission did recognise the unprecedented threats to forests, its much-needed plans to monitor and restore them are too timid. The Commission also proposes to use forests to offset emissions from the agriculture sector.

Here are Fern’s forest and climate campaigners’ reactions to the Renewable Energy Directive and the Regulation on the inclusion of greenhouse gas emissions and removals from land use, land use change and forestry (LULUCF).  

NB The forest strategy is not yet online despite being announced in the press conference. We understand the Forest Strategy text will be online on Friday, at which point we will issue our commentary on that text.

On the Renewable Energy Directive (RED)

Martin Pigeon, Forest and Climate Campaigner:

This proposal keeps the bioenergy incentives that are already accelerating climate breakdown and destroying nature today.

Instead of basing policies on its scientific advisors’ warnings about the real-life impacts of burning forest biomass, the European Commission gave in to relentless pressure from the bioenergy industry and its allies. It chose to sacrifice forests rather than admit that current EU bioenergy policy is making the climate crisis worse.

The Commission is obviously aware of the problem, but none of its proposals will prevent forest destruction from escalating: its proposed increases renewable energy targets will mean many coal-fired power plants in Europe will switch to biomass.

The final decision now rests with the European Parliament and Member States. They still have the chance to protect our forests, by excluding forest biomass from the RED.”

On the regulation on the inclusion of greenhouse gas emissions and removals from land use, land use change and forestry

Kelsey Perlman, Forest and Climate campaigner:

For the EU to achieve carbon neutrality by 2050, healthy, diverse forest ecosystems must flourish. There is nothing in the Fit for 55 package that will make this happen.

While the LULUCF proposal includes some timid steps to curtail biodiversity loss, they are unfit to address the gargantuan demand for wood stemming which is driven by the renewable energy directive and unfettered promotion of the bioeconomy. The remedies proposed are like putting a band aid on a broken bone.

On forests offsetting the emissions of the agriculture sector

Kelsey Perlman, Forest and Climate campaigner:

The Commission decision to go ‘all in’ on carbon offsetting gives the agriculture sector a ‘get out of jail card’ from 2030. Instead of dealing with emissions from livestock and fertiliser they will be allowed to offset the work to someone else, somewhere else – in this case Europe’s forests. Forests are already being barraged by increased logging, temperatures and insect outbreaks, they cannot also carry the burden of offsetting the emissions of Europe’s worst polluters.


  • Today’s announcement is the outcome of months of intense industry lobbying and internal wrangling within the European Commission. More than 250,000 people and 500+ scientists had urged the Commission to exclude the burning of forest biomass from counting towards renewable energy targets.
  • The legislative proposal will now go to the European Parliament and the EU Council, the two EU co-legislators who need to adopt the text in similar terms, a process usually taking up to two years.
  • EU forests are in a dire state: they are absorbing 15 per cent less carbon dioxide than they were 20 years ago, due to harvesting and clear cuts. Healthy biodiverse forests are being replaced by monocultures: an area larger than Greece (14.5 million hectares) is now covered by tree-plantations. If current management practices continue, by 2050 the EU forest sink will be halved. 
  • Meeting the EU’s goal of being carbon neutral by 2050 will require that forests remove a vast amount of carbon dioxide (CO2). A recent Greenpeace study found that if logging in Europe’s forests was reduced by a third, their CO2 absorption potential could be increased from 245.4 million tonnes of carbon dioxide per year to 487.8 million tonnes – more than the entire annual domestic emissions of France.

On the Commission proposal for the Renewable Directive

  • The proposal removes financial incentives from burning some types of wood (such as tree roots and stumps, sawn logs, veneer logs) but fails to tackle the main problem, the existence of an economic incentive to harvest and burn forest biomass. It also proposes no-go areas for extracting forest biomass in primary forests, but since primary forests are very rare in Europe (max. 2-3% of the total forest cover) and the Commission has proposed these areas be protected anyway, there is nothing additional there. Finally, the new language added to Article 29, the sustainability criteria, goes in the right direction but only refers to the existing, insufficient risk-based approach: it is not binding per se, only advisory.
  • In 2018, more than 10 billion euros in public subsidies were given to energy producers burning biomass in the EU. The stakes are increased by EU ‘green’ finance planswhich will follow the RED in incentivising private investments in ‘sustainable biomass’, and the foreseeable increase of carbon prices which might make operating biomass power plants profitable as long as this source of energy wrongly remains labelled as “zero carbon”. The Netherlands just decided to stop issuing these harmful subsidies for new plants.
  • A recent report by the Commission’s own forest scientists concludes that burning ‘coarse woody debris’ such as whole trees will increase emissions for decades compared to fossil fuels, even coal – biomass combustion emits more CO2 than coal per unit of energy produced.
    Public support, according to the EASAC (another scientific body advising the Commission), should only be granted to biomass feedstocks compatible with the Paris Agreement, what the JRC called “Fine Woody Debris” (wood smaller than 10cm diameter with bark), provided enough is left in the forests to replenish soils. Yet, the amount of forest biomass that would be covered by this category is very limited. Given the weak traceability of wood and the importance of forest ecosystems, it is safer to remove the incentive to use forest biomass entirely and only keep it for the rest (residues from saw mills for instance).
  • Coal-fired power plants switching to biomass is the main immediate threat to European forests. Such conversions are enabled by bioenergy incentives, particularly in regions where coal is still a big part of the energy mix such as Germany, Poland, the Czech Republic. Volumes are huge: in the UK, Drax says it burns about 7 million tonnes of wood pellets per year in its power station in Yorkshire. This is more than the entire UK’s annual wood harvest (in 2020 it was 10.8 million tonnes of green wood which is up to 50 per cent heavier than dried pellets). Today, electricity generation from biomass represents about 7 per cent of the UK’s total electricity production. Given such volumes, most of the biomass is imported, notably from the United States where logging for bioenergy is destroying forests and communities. Even in nuclear France, the former coal power plant of Gardanne, France, just resumed operations with biomass, and this small plant will burn 850,000 tonnes of wood per year, representing 10 per cent of the total amount of wood used for energy in France in 2020 and 2.2 per cent of France’s total wood harvest.  
  • The European Commission is well aware of the facts, and has proposed an exclusion of subsidies for wood for “electricity-only-installations” except in “region identified in a territorial just transition plan… due to its reliance on solid fossil fuels,” in other words coal-dependent regions, where the threat is most acute and a meaningful exclusion would be the most needed. Indeeed, most power plants combine electricity and heat production, not electricity only, so this exclusion will hardly apply anywhere in Europe.
  • Biomass is incorrectly defined in EU law as a “zero carbon” energy source on the grounds that emissions are accounted for in the LULUCF sector rather. This loophole has caused the EU to increasingly rely on forest biomass to achieve its renewable energy targets despite the fact that forest bioenergy‘s additional emissions accelerate climate change. Biomass burning has doubled since the early 2000s and has already surpassed projected levels. Half of all harvested wood in Europe is now burnt for energy, and 18 per cent of all renewable energy comes from this source. The EU’s addiction to bioenergy has exerted huge additional pressure on forests, meaning EU forests absorb 15 per cent less carbon dioxide since 2005

On the Commission proposal for accounting emissions from the Land Use, Land Use Change and Forestry (LULUCF)

  • The Commission also proposes an increased target for carbon dioxide removals, from 225 million tonnes (Mt) of carbon to 310 Mt. This is a slight increase in ambition but well below the scientific potential of biodiverse ecosystems in Europe (600Mt). It is particularly problematic that part of those carbon removals will still be used for offsetting other sectors’ emissions.
  • Currently, Member States are asked to report on the carbon dioxide emissions of their LULUCF sector. The Commission now proposes that they factor in some biodiversity elements through reporting under the Governance Regulation, such as high carbon stock land, land units subject to protection and land units subject to restoration. While a step forward, this must be linked to clear objectives to restore forests across Europe.
  • Post-2030, the Commission proposes to incrementally integrate LULUCF with other emitting sectors. First by bundling it with agriculture, including non-carbon dioxide agricultural emissions mainly from cows and fertilisers, then with other sectors. Only the merger with agriculture is mentioned in the text of the law; the explanatory memorandum suggests a wider used of land offsets after 2035.
  • Increasing land offsets would allow other sectors to delay their urgently needed decarbonisation. The Commission is suggesting to increase the removal target for the land sector, but if trading is allowed, this will only mean that other sectors will be able to offset more.
  • Over 15 years ago, the European Commission concluded that forest credits should not be included in the EU Emissions Trading System (ETS), due to the possibility of market flooding and governance problems. The science hasn’t changed since then. The fossil carbon pool and atmospheric carbon pool remain separate. There are still huge uncertainties in data around forest carbon removals, and forest stocks continue to be impermanent.

Categories: Press Releases, Bioenergy, Forest Restoration, Land Use, Land Use Change and Forestry (LULUCF), Carbon Trading

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