Need for a scientific basis of EU climate policy on forests

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Increased harvesting levels have a negative impact on the climate because the standing forest carbon stock is immediately reduced when the forest is harvested. [Dru!/Flickr]

A group of scientists has sent an open letter to EU decision-makers, warning that a planned increase in harvesting levels of forests for bioenergy use risk having a negative impact on the climate.

This letter is a shorter version of an open letter signed by 190 scientists from the EU and US. The full letter and list of signatories can be downloaded here.

We, the undersigned, would like to express our grave concern over the scientific basis of recent political developments on the LULUCF Regulation and sustainability criteria for biomass in the Renewable Energy Directive. We urge you to support the highest integrity of these two strongly interlinked dossiers in order to ensure they deliver on the EU’s global commitments to mitigate climate change and halt biodiversity loss.

The LULUCF policy regulates the inclusion of greenhouse gas emissions and removals from land use, land use change and forestry into the 2030 climate and energy framework. A critical feature of the LULUCF Regulation is how the forest reference level for Member States will be specified. The promotion of an increase in active forest management encourages increased harvest levels in order to substitute fossil-derived fuels and products with wood and bioenergy without accounting for their full climate impacts. This approach risks having adverse effects on climate, biodiversity and resilient ecosystems by emitting more greenhouse gases, influencing biophysical processes and causing additional habitat loss – accumulating evidence suggests that the proposed strategy risks being counterproductive.

Increased harvesting levels have a negative impact on the climate because the standing forest carbon stock is immediately reduced when the forest is harvested. It may take decades to centuries until the former level of the carbon stock is restored by regrowth.[i],[ii] About 60% of the wood in Europe is used for (short-lived) energy and pulp[iii],  where much of the carbon is released immediately. Harvesting also leads to other greenhouse gas emissions, and influences the climate via biophysical processes such as albedo, evapotranspiration, forest structure and cloud-formation.[iv],[v],[vi]

The forest reference levels should constrain the Member States’ ‘business as usual’ utilization of forest resources. Without such regulation the emission levels of certain Member States will increase, possibly even further triggered by subsidies for bioenergy.[vii] If Member States include future policies in their reference level, they will be able to increase forest bioenergy production without fully accounting for its emissions. The forest reference levels should therefore exclude all policies from 2009, since the introduction of the Renewable Energy Directive, to ensure all emissions from increased harvests for bioenergy are accounted for.

Honest accounting of the climate impacts of forest use in the LULUCF Regulation would also stimulate carbon is captured in wood products that live longer, such as for construction, where wood can replace the use of high-carbon materials such as steel and concrete. In general, reduced production and consumption patterns are necessary to mitigate climate change. Environmental impact assessments including life-cycle -and cost-benefit analyses of forest management and forest products should determine how to utilise forest resources sustainably.

Bioenergy from forest biomass is not carbon-neutral and can have seriously negative climate impacts. The combustion of forest biomass generally releases more carbon dioxide to the atmosphere than fossil fuels, because of the lower energy density and conversion efficiency of biomass (more has to be burnt relative to fossil fuels).[viii],[ix],[x],[xi] It is therefore important for the EU’s renewable policy to exclude the use of biomass feedstocks with long pay back times for energy, because these are unlikely to make an effective contribution to meeting the Paris Agreement target to limit global warming to well below 2 degrees and aspire to 1.5 degrees.

In the face of climate change more resilient forests are needed. Forest management methods have led to an increase in homogeneous forests, making them more vulnerable to the effects of climate change. Natural forest ecosystems, with a diversity of species, show a greater resilience and provide a higher number of ecosystem services, such as biodiversity protection and carbon storage. [xii],[xiii],[xiv],[xv] Management strategies, such as continuous-cover silviculture or management to enhance mixed evergreen deciduous stands, can enhance the multi-functional role of forests.

Urgent action is needed in combating the threats of climate change and biodiversity loss. The EU needs to set an evidence-based precedent on the implementation of Paris Agreement and consider large-scale impacts on forests and the multi-functionality of forests.

To ensure emissions from forestry are mitigated and correctly accounted, we urge the EU to:

LULUCF Regulation

  • Ensure policies from 2009 are not included in forest management reference levels to ensure emissions from bioenergy are accounted.
  • Climate impacts of forests are fully accounted for to incentivise using wood in long-lived harvested wood products and standing forests.
  • Promote maintenance of and increase in the EU forest sink; the EU should make an assessment on how forests can safely and sustainably contribute to increasing climate ambition.
  • Deforestation is actively discouraged.

Renewable Energy Directive (recast)

  • Introduces effective sustainability criteria for the use of forest biomass for energy.
  • Restricts the use of feedstocks with long pay-back periods, such as roundwood.

We further encourage Member States to assess the potential impacts of the implementation of the EU’s climate policies on biodiversity, and on the objectives under the EU Biodiversity Strategy and the Birds and Habitat Directives.


[i] Bellassen V. and Luyssaert S. (2014). Managing forests in uncertain times. Nature 506, 153–155.

[ii] Sievänen R. et al. (2014). Carbon stock changes of forest land in Finland under different levels of wood use and climate change. Annals of Forest Science 71, 255–265.

[iii] Mantau U. (2012). Wood flows in Europe (EU27). Project report. Commissioned by Confederation of European Paper Industries (CEPI) and European Confederation of Woodworking Industries (CEI-Bois).

[iv] Ellison D. et al. (2017). Trees, forests and water: cool insights for a hot world. Global Environmental Change 43, 51–61.

[v] Jackson R. et al. (2008). Protecting climate with forests. Environmental Research Letters 3, 44006.

[vi] Pielke R. et al. (2002). The influence of land-use change and landscape dynamics on the climate system: relevance to climate-change policy beyond the radiative effect of greenhouse gases. Philosophical Transactions of the Royal Society of London A 360, 1705–1719.

[vii] EASAC (2017). Multi-functionality and sustainability in the European Union’s forests. EASAC policy report 32.

[viii] Ståhls M. et al. (2011). Impacts of international trade on carbon flows of forest industry in Finland. Journal of Cleaner Production 19, 1842–1848.

[ix] JRC (2013). Carbon accounting of forest bioenergy. European Commission, Joint Research Centre – Institute for Energy and Transport.

[x] Smyth C. et al. (2016). Climate change mitigation potential of local use of harvest residues for bioenergy in Canada. GCB Bioenergy.

[xi] Soimakallio S. et al. (2016). On the validity of natural regeneration in determination of land-use baseline. International Journal of Life Cycle Assessment 21, 448–450.

[xii] Balvanera P. et al. (2013). Linking biodiversity and ecosystem services: current uncertainties and the necessary next steps. BioScience 64, 49–57.

[xiii] Gamfeldt L. et al. (2013). Higher levels of multiple ecosystem services are found in forests with more tree species. Nature Communications 4, 1340.

[xiv] Tilman D. et al. (2014). Biodiversity and ecosystem functioning. Annual Review of Ecology, Evolution and Systematics 45, 471–93.

[xv] Holm, S-O. (2015). A Management Strategy for Multiple Ecosystem Services in Boreal Forests. Journal of Sustainable Forestry 34 (4): 358-379.