The Environment Committee's position ignores the realities of forest management measures. It is worth remembering that biomass suitable for bioenergy - which has no other use than as energy - is the result of regular forestry operations. Biomass from both industrial side streams and forestry operations is used to replace fossil fuels and energy from outside the EU. Without this, the management work that is essential for the health of forests may not be carried out.  

If implemented, the views of Parliament's Environment Committee would jeopardize the heating possibilities from renewable energy sources and spoil many Member States' chances of meeting their renewable energy targets.   

Extending cascading and waste hierarchies to the wood market would create an unprecedented administrative burden on wood supply logistics chains and make it much more difficult for renewable wood energy to compete with fossil fuels in the fuel market. Dividing the different varieties of wood into primary and secondary biomass would lead sustainability regulation into years of uncertainty, with repercussions for the bioenergy investment climate. It would also ignore the risk-based approach to sustainability recommended e.g., by OECD and implemented by current RED in many MS’s. On forests, the Committee’s proposals would lead to the partial or even total exclusion of normal commercial forest areas from the timber market as so-called no-go areas. The negative effects, for example on the collateral values of these forests, would be dramatic.  

In a situation where the whole of Europe is struggling to move away from Russian fossil energy sources and where the prices of competing fossil energies have risen, causing a widespread debate in Europe about energy poverty, the proposals of the Parliament's Environment Committee to make it more difficult to access the EU's most important source of renewable energy are strongly alien to the everyday lives of ordinary Europeans. Wood fuels accounted for 28% of total energy consumption in Finland in 2020.  

Regarding the LULUCF regulation which focuses on the climate targets in the land-use sector, the ENVI Committee agreed that it is necessary to tighten the climate targets by -50MtCO2eq from the COM proposed -310MtCO2eq. The tightening at EU level corresponds roughly to the annual volume of industrial timber harvested in Finnish private forests. Even the Commission's base proposal would already tighten the EU-level climate targets from their current level with high ambition level. Several Member States have stated that they will not be able to meet even the targets proposed by COM. Parliament's Environment Committee is also proposing separate targets for agricultural land. Promotion of biodiversity objectives, which still have unclear impacts, will be connected to climate accounts. MTK regrets that the European Parliament's Environment Committee has not been able to identify any new sources of funding for implementation of ambitious climate targets. The role of the carbon certification legislation to be adopted later this year is also left completely unclear in the proposal.  

The redline in EU's energy and climate policy appears to be contradictory. On 18 May, the REPowerEU, plan to improve the EU's energy security, was published. The plan makes no mention of bioenergy. It aims to more than double biogas production in the EU by 2030. It is fair to ask who dares to make long-term commitments to biogas investments when the political climate for other bioenergy has turned 180 degrees in a few years? Indeed, it seems that the EU's energy security will increasingly rely on expensive imported fossil fuels for which Europeans compete with others on the world market. This will not reduce climate emissions and will not improve the trade balance neither of EU. 

More information: 

Anssi Kainulainen  

Energy and climate expert, MTK 

anssi.kainulainen@mtk.fi 

+ 358 50 596 1541 

topics: forestry, eu, metsä, bryssel, fit for 55, lulucf