Sustainability criteria for renewable energy (RED II) must take account of sustainable forestry and sustainability of agricultural biomass from peatlands in Finland



The purpose of the sustainability criteria for renewable energy is to curb indirect emissions resulting from changes in land use and to ensure that raw materials are produced in a socially, economically and ecologically sustainable way. The first sustainable criteria for bioenergy were included in the RED directive (Renewable Energy Directive), the purpose of which was to increase the use of energy from renewable sources. The first proposal concerned liquid biofuels only. The RED II directive currently under preparation also includes solid biomasses.

European Commission’s proposal is a good basis for forests, but brings a threat scenario for agriculture

The RED II proposal of the European Commission updates the sustainability criteria in the Renewable Energy Directive. For the most part, the European Commission’s proposal is good with respect to forest biomasses because the assessment would be founded on a risk-based country-specific assessment. With the sustainability criteria, Finnish forest owners would be able to be recognised for their internationally sustainable forest practices, but the special characteristics of Nordic forestry must be taken into account when drawing up the criteria.

The proposal for a directive calls into question the sustainability of agricultural biomasses produced in peatlands and is therefore not in line with the Paris climate agreement. The objective of the climate agreement is to safeguard the preconditions of food production unlike the European Commission’s proposal for sustainability criteria. The non-sustainability of biomass for energy use undermines cultivation of peatland and, consequently, food production. This is contrary to all of the three dimensions of sustainable development. Agricultural biomasses used in energy production consist of by-products to a significant degree, and it is not justifiable to limit their use regardless of the subsoil of the field.

The policy of the Environment Committee of the European Parliament would increase red tape and undermine investments in bioeconomy

The Environment Committee of the European Parliament has published its draft report on the proposal of the European Commission. However, unfortunately the draft does not take into account the diverse role of sustainable forestry in climate change mitigation. If implemented, the Environment Committee’s view would increase unnecessary red tape and undermine investments in bioeconomy and the EU’s long-term strategy towards a carbon-neutral society.

The following issues must be taken into account in the sustainability criteria:

1. The future sustainability criteria must also allow bioenergy production with raw materials originating from sustainably managed peatland forests.

The current proposal of the Environment Committee on the sustainability criteria does not take into account the special characteristics of Finnish forests as it would label all peatland forests as a non-sustainable source of raw materials. This would increase unnecessary red tape and uncertainty in the forest sector. In the long term, the role of peatland forests as a source of raw materials in bioeconomy will be emphasised as, according to the estimate of the Natural Resources Centre, the share of drainage areas in the felling potential in Finnish forests is anticipated to rise to about 20 per cent.

2. The cascade principle cannot and need not be applied to timber and other raw materials because the markets direct the use of raw materials in a flexible way towards the best areas of application.

According to the cascade principle, materials are utilised in reuse and recycling chains in addition to processing. Artificial restrictions concerning, for example, the utilisation of small-diameter stemwood and pine oil in bioenergy production would disrupt the forest sector as a whole and prevent the creation of new innovations. The European Commission has also outlined that it will not create a directive based on the cascade principle, but general guidelines, and therefore it would be consistent not to include the cascade principle in other directives either.

3. A country-specific risk-based assessment must be used as a basis when assessing the sustainability criteria in order to avoid unnecessary red tape.
Existing national legislation as well as research data and experts must be utilised when examining the sustainability criteria. Forest certification verifies sustainability on a market basis, but the certificates must not be set as a default to meet the sustainability criteria.

4. The use of biomass from peatlands must not be prevented. According to the proposal, biomass from peatlands would be non-sustainable. From here, it is only a very small step to non-sustainability of food and feed growing in cultivated peatland. Cultivated peatland needs plant production and crop cover in order to be able to reduce carbon dioxide emissions. Therefore, the directive must not prevent the use of agricultural biomasses as bioenergy.

5. The definition of agricultural peatland requires clear criteria and extensive soil mapping with uniform criteria. In Finland, even very thin areas of peat or humus soil have been classified as organic (rich in carbon).

Further information:
Anssi Kainulainen, Energy Specialist, +358 50 596 1541
Liisa Pietola, Head of Environmental Affairs, +358 50 438 4014

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