The European Commission was sent back to the drawing board on the EU’s renewable energy directive overhaul after an internal assessment of its draft proposal concluded that it failed to analyse the potential environmental risks of increased bioenergy use.
The European Commission’s Regulatory Scrutiny Board, an in-house independent body overseeing the quality of EU legislation, sent a negative opinion on the EU executive’s draft renewable energy directive.
In the opinion, dated 19 April, the board said the Commission’s cost-benefit analysis of the directive contained “significant shortcomings”.
“The presentation of the analysis and comparison of the options is often confusing or incomplete,” the board said, adding this was the case “in particular” when it comes to “the options related to bioenergy” and their likely impact on EU member states.
“The report should clarify whether the proposed sustainability criteria for biomass and the increased use of bioenergy (especially after 2030) are aligned to the Green Deal’s ‘do no harm’ principle, in particular for air pollution,” the board said in its opinion, obtained by EURACTIV.
The European Commission is currently preparing an update of its renewable energy directive as part of a broader package of climate and energy laws due to be presented on 14 July.
A leaked draft of the proposal, seen by EURACTIV, confirmed the bloc’s objective of sourcing 38-40% of its energy from renewables by 2030, roughly doubling the share of solar, wind and other renewables in Europe’s energy mix by the end of the decade.
Options considered in the proposal include a “targeted strengthening of the current bioenergy sustainability criteria” listed in the directive, a ban on logging in primary or old-growth forests, and possible national caps on the use of stem wood above a certain size for energy.
Biomass currently represents almost 60% of the EU’s renewable energy, more than solar and wind power combined, according to the EU’s statistical office, Eurostat. Bioenergy consumption in Europe increased by more than 69% between 2005 and 2016, and this trend is expected to continue in the coming decades, according to the EU executive.
But the regulatory scrutiny board said the Commission’s impact assessment did not sufficiently look into the potential environmental risks of increased biomass used for electricity production.
“The impact analysis for measures regulating bioenergy seems too narrow,” the board said in its opinion.
“The report should analyse the effects on the bioenergy sector resulting from the increasing demand for renewable energy sources and clarify assumptions, uncertainties and potential risks,” it added, saying those are particularly relevant for sectors like aviation and maritime transport which are hard to electrify.
Environmental groups say the Commission seemed complacent about the environmental risks associated with increased bioenergy use. This is especially the case for the period after 2030, where the EU executive expects overall bioenergy demand to grow “by 65-80%” in 2050 compared to 2030.
“The Regulatory Scrutiny Board was right to send [the Commission] back to the drawing board for failing to consider the harm that burning forests does to the air we breathe, nature and our climate,” said Martin Pigeon, a campaigner at FERN, an organisation dedicated to protecting forests and the rights of people who depend on them.
“The impact assessment comes across as a desperate defence of the status quo,” added Alex Mason, senior policy officer at the WWF EU office. “It seems somehow to believe that the climate won’t notice tree trunks being burnt for energy if they’re not of industrial quality, or result from salvage logging after a storm,” Mason told EURACTIV in emailed comments.
In particular, the effects of bioenergy on air pollution have not been sufficiently explored, the Commission’s regulatory scrutiny board noted in its opinion.
“Burning wood and other biomass is a huge source of air pollution in the EU,” said Mary S. Booth, director at the Partnership for Policy Integrity, a US-based research group, which published a report last year exploring how the EU’s renewable energy directive had increased forest destruction across the globe.
Booth drew attention to an impact assessment done in the US under the Obama administration, which included detailed analysis in terms of human lives lost or saved due to air pollution.
“It is striking to me that the impact assessment for the renewable energy directive is so amateurish in this regard,” Booth told EURACTIV in emailed comments. “The impact assessment does mention air pollution impacts but gives the issue short shrift,” she added.
“You might ask the people responsible for writing the impact assessment whether they’ve done any modelling to assess how many lives would be saved if air pollution from wood-burning was reduced,” she said.
Not all biomass is carbon neutral
Mason also pointed out that the Commission had “bizarrely” ignored a report from its own research body, the Joint Research Centre (JRC), published earlier this year, which warned about potential “lose-lose” situations where bioenergy exacerbates climate change and damages forest ecosystems.
Bioenergy is currently considered carbon neutral by default under the EU’s renewable energy directive, but activists say this principle should be reconsidered in view of the latest scientific findings.
According to the WWF, the JRC report was a recognition that “most forest biomass produces more greenhouse gas emissions than coal, oil and gas”.
In 2019, a group of environmental NGOs including the WWF filed a lawsuit against the European Union for considering biomass as a “renewable energy” which is inherently climate neutral. The NGOs were later dismissed in the case.
Yet even industry figures acknowledge that not all biomass brings benefits to the climate, insisting that only low-value wood and forest residues should make the cut under EU law.
“We agree that not all biomass should automatically be categorised as carbon neutral,” said Jennifer Jenkins, chief sustainability officer at Enviva, a US-based producer of industrial wood pellets who spoke at an EU event last year.
Bioenergy Europe, a trade organisation, agrees that the Commission’s draft impact assessment is flawed, but for opposite reasons – because it doesn’t sufficiently take into account the benefits of biomass, for example in displacing fossil fuels.
“The leaked impact assessment’s policy options described are often based on unwarranted assumptions while the benefits of fossil fuels substitutions are largely disregarded,” said Jean-Marc Jossart, secretary general of Bioenergy Europe.
Jossart also drew attention to “socio-economic implications for forest-rich countries” like Sweden and Finland, where bioenergy provides a large number of jobs in the renewable energy sector.
Sweden and Finland came under the spotlight last month for exerting pressure on the European Commission over forestry and biomass rules in the bloc’s green finance taxonomy.
Campaigners now say similar pressure is being exerted when it comes to rules on biomass contained in the bloc’s revised renewable energy directive.
“It’s time for [the Commission] to defend the public interest rather than pandering to the Finnish and Swedish governments, and to the bioenergy industry desperate to defend their billions in undeserved subsidies,” said FERN’s Martin Pigeon.
RSB opinion REDIII
> Read the opinion from the Commission’s regulatory scrutiny board below or download here:
[Edited by Josie Le Blond]