DECEMBER 2016

BIOENERGY IN THE EUROPEAN COMMISSION’S PROPOSED POST-2020 EU RENEWABLE ENERGY DIRECTIVE: AN ANALYSIS OF PROPOSALS AND IMPACTS

Summary the expansion of wood-based any credible, independent bioenergy. verification and auditing The European Commission’s system. Furthermore, standards proposals for a new, post-2020 The Commission proposes cannot address indirect impacts Renewable Energy Directive to extend the principle of or make fundamentally (RED) fail to address the serious sustainability and greenhouse unsustainable consumption negative impacts of large- gas standards, which have levels sustainable scale biofuel and wood-based applied to liquid biofuels bioenergy expansion which since 2010, to wood-based Biofuelwatch supports the has been underway since the bioenergy, as well as other solid call, set out in a declaration current RED came into force biomass and biogas (albeit with signed by120 civil society in 2010. Instead of ending different standards in the case organisations in early 2016, to incentives for biofuels, the of wood-based bioenergy). remove bioenergy from the proposed new RED allows for However, no evidence exists to scope of the RED, to ensure that a 40% greater use of food- show that the biofuel standards only genuinely renewable and based biofuels such as palm have been in any way effective. low-carbon forms of energy and soybean oil in 2021, and a Not only are the existing biofuel are support, and to initiate still significant use of them by standards and the proposed meaningful economic and 2030. It seeks to boost the use wood-based bioenergy social changes to reduce the of advanced biofuels for which standards extremely weak and EU’s excessive and wasteful the technologies to produce reliant on flawed methods consumption of energy and them commercially have not for calculating greenhouse other resources. so far been developed. And gas emissions from bioenergy, it threatens to further boost but there is no proposal for

Background

On 30th November, the in the European Council, the Directive (RED) has first and European Commission European Parliament, and the foremost benefited large- published the long-awaited European Commission itself. For scale bioenergy, which makes draft of the post-2020 EU a new directive to come into up almost two thirds of all Renewable Energy Directive, effect in 2020, the final version energy classed as renewable1. which will replace the current will have to be approved by Bioenergy consists of biofuels directive, in place since 2010. 2019, likely as part of a wider made from vegetable oil, This proposal will be discussed ‘Climate and Energy Package’. ethanol made from sugar and and likely amended between starch, biogas made from the member states represented The existing Renewable Energy anaerobic digestion of crops, grass, manure and food waste, liquid biofuels has been a major with bioenergy in the current and wood, straw and other cause of both in recent years; RED. This briefing summarises solid biomass burned for heat the main new proposals as they and electricity. The bulk of • More landgrabbing, relate to bioenergy. energy generated from biomass displacement and other in the EU – and worldwide – injustices suffered by Biofuels in the new RED comes from burning wood. communities mainly in the global South as a result of the proposal: The inclusion of bioenergy in rising demand for agricultural Current provisions: EU renewable energy policy products and wood for energy is controversial: in February in the EU; The current RED includes 2016, 120 civil society groups a special 10% target for worldwide demanded that • More depletion and pollution renewable energy in transporti, bioenergy must be excluded of freshwater and soils as which is primarily being from the EU’s definition of intensively managed crop and translated into a biofuel target. renewable energy2. After all, it tree monocultures expand In 2015, the EU decided to is difficult to see how burning with the growing demand for cap the maximum contribution biofuels or wood meets the bioenergy; from food/land-based biofuel International Energy agency’s feedstocks, such as virgin plant definition of renewable energy, • Air pollution and public oils, sugar crops and cereals, which is “energy derived from health: Tree plantations, at 7% of all transport fuel by natural processes (e.g. sunlight oil palm, soya and other 2020. It was a disappointing and wind) that are replenished crop plantations that supply compromise which aimed to at a faster rate than they are wood pellets or biofuels are tackle indirect land use changeii, consumed”. The expansion of sprayed with harmful agro- but which allows a major, i.e. bioenergy under the current toxins. And the proliferation a 40% future expansion of RED has had multiple negative of wood boilers and wood- the very feedstocks which it impacts3, which include: burning power plants is seeks to limit. Food- and land- causing significant increases based biofuels accounted • Climate impacts: The in air pollution, especially for just 5% of EU road and emissions of greenhouse gases small particulates linked to rail transport fuel in 20154. tend to be no better and are respiratory and heart problems The existing RED includes often worse for large-scale in many parts of the EU; biofuel greenhouse gas and bioenergy than for the fossil sustainability standards, which fuels they are meant to replace, • Competition with wind and have been heavily criticised as provided all direct and indirect solar power and a distraction weak and insufficient by NGOs. impacts are accounted for; from the urgent need to reduce For example, they include the EU’s wasteful energy no social standards, i.e. no • Impacts on forests and other use: The RED sets an overall provisions to protect human ecosystems: Wood-based renewable energy target of rights, land rights or workers’ bioenergy is often associated 20% by 2020. Within that rights, and greenhouse gas with more clearcutting of target, bioenergy competes ‘savings’ are calculated using a forests and greater use of against wind and solar power, flawed methodology which, for destructive logging practices, not against fossil fuels. The false example, ignores all emissions while tree and crop plantations belief in a future ‘bioeconomy’ from indirect land use change. for energy replace forests, is further delaying urgently biodiverse grasslands and other needed measures to drastically How do the new proposals ecosystems; reduce the EU’s energy and differ from current provisions? resource use. • Greater food price volatility The generic renewable energy and worse food spikes: Sadly, the European Commission for transport target would be Competition for land caused appears to have learned little abolished; by the increasing demand for from the disastrous experience i. Shipping and aviation are ignored when calculating the overall volume of transport fuels, but biofuels used in either sector can count towards meeting the target. ii. Indirect land use change happens when land previously used to grow food or animal feed is instead used to grow biofuel feedstock, causing forests and other natural ecosystems to be converted to agriculture to grow food or feed instead. There will be one new target derived from wood, too. Existing biofuel refineries for “advanced” and residue- across the EU have a large and waste-based biofuels listed What are the problems with overcapacity8, i.e. they in a separate Annex, as well those proposals? can significantly ramp up as for fuels made from landfill production in future, without gas, plus renewable electricity Despite the overwhelming any new plants being built. Yet used in transport. The list of evidence of harm caused by they will be entirely exempt biofuels which count towards food- and other land-based from stricter greenhouse gas this target includes biofuels biofuels, the new proposal still standards. made algae, from waste sees a significant role for them; including Municipal Solid Waste Wood and other solid and used cooking oil, and “Advanced biofuels” made biofuels made from residues from solid biomass (cellulosic biomass in the new RED such as tallow (a slaughterhouse biofuels) or from algae, as proposal residue), agricultural residues, well as fuels made from manure and sewage sludge, solid non-biological waste Current provisions: and “wastes and residues are not commercially viable from forestry and forest-based with existing technologies. Wood-based bioenergy is industries”. It also includes Serious attempts at producing being promoted mainly by cellulosic biofuels made from cellulosic and algal biofuels virtue of counting towards the wood and from grasses such as have been ongoing since the overall 20% renewable energy miscanthus or ryegrass. Those 1910s and 1970s respectively, target by 2020 (and interim particular biofuels will need to without any evidence of a targets for earlier years). There make up 1.5% of transport fuels major breakthrough5. The only are no greenhouse gas and at the start of 2021, rising to at exception are liquid fuels made sustainability standards for solid least 6.8% by 2030. The share from biomethane, which can biomass, only for biofuels and of used cooking oil and animal be used in cars designed to run bioliquids. fats within that target will be (partly or fully) on gas; limited; How do the new proposals Using residues for biofuels can differ from current provisions? Biofuels and bioliquidsiii made displace their existing uses and from virgin plant oils, sugar cause previous users to turn to Biomass sustainability standards crops or starch (e.g. corn or virgin plant oils or fossil fuels will be introduced. For ‘energy wheat) will still count towards instead. For example, tallow crops’, such as miscanthus, the overall renewable energy (animal fat) use for biofuels has poplar or willow short target, which will be gradually been linked to greater palm rotation coppicing, the same increased from 20% in 2020 to oil use for soap and cosmetic standards as for biofuels will 27% in 2030. Their share will be products6, whereas using tall apply. For wood from forests capped to 7% of total road and oil (made from a residue of and from tree plantations, rail transport fuel use initially, pulp and paper production) different standards will be reducing to 3.8% in 2030; for biofuels can cause chemical introduced. The proposed industries to use more fossil sustainability standards consist Existing sustainability criteria fuels7; of minimum standards for for biofuels derived from “forest management”, such agricultural crops (including Existing greenhouse gas and as minimising impacts on soils palm oil) will remain largely sustainability standards are to and biodiversity, and replanting unchanged, and no changes are be continued, even though logged forests and plantations proposed to the methodology there is no evidence of their or allowing them to naturally for calculating “greenhouse gas effectiveness, i.e. of them regenerate. Member States can savings”. Minimum greenhouse having minimised the harm choose to legislate for stricter gas ‘savings’ which must be caused by biofuels which they biomass sustainability standards achieved will be gradually are meant to address. The than those set out in the new raised, albeit only for biofuels European Commission does RED – which has not been produced in new plants. not even know whether any the case, and is not proposed New sustainability standards consignments of biofuels have for biofuels and bioliquids proposed for wood-based ever been deemed to breach standards. bioenergy will apply to biofuels any of the standards; iii. The term bioliquids refers to liquid biofuels used for electricity, heating and/or cooling. As is already the case for the new Directive has been that would otherwise have one biofuels and bioliquids, energy adopted. At the same time, to fibre board production being companies can “prove” a clause in the current RED burned for energy, resulting in compliance with sustainability which calls on Member States fibre board producers resorting standards by one of two means: to only support biomass with a to increased logging); They can pay a consultancy minimum conversion efficiency company of their choice to of 70% is to be abolishediv. Given the very high existing provide a report confirming share of bioenergy in the that standards are being met What are the problems with “renewable heating and – or they can rely on voluntary those proposals? cooling” sector across the EU, certification schemes accredited there is a significant risk that by the European Commission; Proposed biomass sustainability encouraging year-on-year standards are so weak as to be expansion of “renewables” in Greenhouse gas standards will effectively meaningless; this sector will cause further be introduced for biomass. The expansion of wood burning methodology for calculating As has been the case of for heat. This would be a “greenhouse gas savings” only biofuel standards, no credible dangerous distraction from the accounts for emissions from independent auditing and priorities in the heating and fossil fuel and fertiliser use verification system is proposed. cooling sector, which are first associated with tree plantations Compliance with standards will and foremost better insulating and with logging, fossil fuel therefore be nothing more than homes and building new homes emissions during transport and a paper exercise. to the highest energy efficiency processing (e.g. in a wood pellet standard, followed by support plant), and those caused by As with biofuels, standards for for genuinely low carbon direct land use change; biomass cannot address indirect renewable energy. Apart from impacts and the sustainability of the impacts on forests and full- Member States should try the scale of demand for wood cycle carbon emissions, biomass to ensure that the share of or other types of biomass; heating has a particularly renewable energy in heating serious effect on air quality and cooling increases by The proposed methodology for and public health: according to 1% every year. This is an calculating “greenhouse gas a World Health Organisation aspirational goal rather standards” ignores the large estimate, 59% of all particulate than a mandatory target, volume of scientific evidence (PM 10) pollution in southern and genuinely low-carbon regarding the carbon debt Germany during the winter alternatives to bioenergy can and life-cycle greenhouse already comes from domestic count towards it. However, gas emissions associated with wood burning10. The World biomass accounted for 84% of wood-based bioenergy. The Health Organisation estimated what is classified as renewable only non-fossil fuel carbon that by 2010, 61,000 premature energy in the heating and emissions which are considered deaths in Europe were cooling sector in 2014, are those from direct land use caused by small particulates with biogas and bioliquids change – but clearcutting a from domestic wood and accounting for a further 3.3%9; forest or turning a biodiverse coal burning combined. This forest into an industrial tree figure could rise considerably Biomass electricity generated in plantations are not classed as if domestic wood heating plants with a minimum capacity land use change. Ignored are expands; of 20 MW will only count the upfront CO2 emissions from towards the renewable energy burning biomass, the time-lag The requirement for larger target if it uses “high efficient biomass plants to operate as between CO2 being emitted cogeneration technology”, by burning wood from trees high efficiency cogeneration unless a Member State notifies and new trees potentially plants might look positive the Commission that their sequestering that carbon in at first sight, although it is security of electricity supplies is future, the loss of carbon important to note that all plants at risk. This minimum efficiency from forests, and all indirect that open before 2020/21 will requirement will only apply to greenhouse gas emissions be exempt. Current wording plants that start operating once (caused for example by residues suggests that this exemption iv. This provision, contained in Article 13(6) of the existing EU Renewable Energy Directive has never been enforced and appears to set out an aspiration only. may cover all future coal (or biomass schemes should this lack of evidence, a similar gas)-to-biomass conversions achieve. model is now to be extended to and all co-firing of biomass biomass. with fossil fuels, because those Conclusions: are existing, not new plants. Excluding bioenergy from the Conversions of fossil fuel power The proposed new Renewable definition of renewable energy stations to biomass are by far Energy Directive fails to reverse would prevent the negative the largest biomass projects the EU’s disastrous biofuel impacts of bioenergy, and at the in the world, with some of policy. Furthermore, it will see same time significantly boost them consuming many millions a significant further expansion low-carbon no-burn renewable of tonnes of wood pellets a of wood-based bioenergy in energy. However, as the year each. Furthermore, the particular, which will cause declaration signed by over 120 definition of a high efficiency more harm to forests and other civil society groups in early 2016 cogeneration plant is far from ecosystems, to communities, points out, this needs to be stringent. It is set out in the EU to public health, and to part of much more far reaching v Energy Efficiency Directive , and the climate. The proposed policy changes to reduce the the UK government has argued sustainability and greenhouse EU’s excessive and wasteful use that its interpretation, under gas standards are ineffective of energy and resources and to which power stations with a except insofar as they may move away from the current mere 35% overall conversion politically legitimise the much growth-oriented economic efficiency can qualify, is expanded use of biomass for model. compatible with that Directive. energy. No evidence has ever This is just half the minimum been published to show that EU efficiency which the existing biofuel standards have been in RED states all supported any way effective, yet despite v. The European Commission has published a proposal for a new Energy Efficiency Directive, too, however they do not propose to change the definition of high efficiency cogeneration.

References

1. ec.europa.eu/eurostat/statistics-explained/index.php/Renewable_energy_statistics

2. www.biofuelwatch.org.uk/2016/bioenergyout-declaration/

3. For full references about the negative impacts of large-scale bioenergy, see www.econexus.info/ publication/bioenergy-out-why-bioenergy-should-not-be-included-next-eu-renewable-energy-directive

4. gain.fas.usda.gov/Recent%20GAIN%20Publications/Biofuels%20Annual_The%20Hague_EU-28_6-29- 2016.pdf

5. See for example www.independentsciencenews.org/environment/biofuel-or-biofraud-the-vast- taxpayer-cost-of-failed-cellulosic-and-algal-biofuels/

6. See webarchive.nationalarchives.gov.uk/20100513200330/http://www.dft.gov.uk/pgr/roads/ environment/renewable-fuels/tallow/tallowfinalresport.pdf

7. See onlinelibrary.wiley.com/doi/10.1111/jiec.12370/pdf

8. In 2015, ethanol refineries in the EU were operating at 75%, and biodiesel and Hydrotreated Vegetable Oil refineries at 44.8% of their capacity: gain.fas.usda.gov/Recent%20GAIN%20Publications/ Biofuels%20Annual_The%20Hague_EU-28_6-29-2016.pdf

9. www.eea.europa.eu/publications/renewable-energy-in-europe-2016

10. www.euro.who.int/__data/assets/pdf_file/0009/271836/ResidentialHeatingWoodCoalHealthImpacts. pdf