Letter on RED III Biomass for electricity

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Dear Member State Attaché,

On behalf of Eurelectric, Europe’s collective electricity industry, we are seeking your country’s support to ensure that the Council is actively involved in the biomass debate in the ongoing trilogues for the Renewable Energy Directive review (RED III).

The European Parliament negotiating mandate proposed introducing a new definition of “primary woody biomass”, to cap its use in the energy mix and electricity and heat production and to withdraw all financial support. All this without having carried out an impact assessment.

As an industry committed to climate neutrality, we already source woody biomass from sustainably managed forests where harvest levels stay below growth such that CO2 stocks in these forests increase. The primary biomass we use are residues or by-products from these forests - i.e., wood unfit for the wood product industry. These residues are recovered within local landscape thresholds respecting biodiversity and soil quality, while also avoiding excessive deposits in the forest with entailed risks of wildfires. We carry out continuous and extensive work to guarantee and document that the biomass we use is sustainable and that the ecosystem and biodiversity are protected.

Paradoxically, the Parliament’s introduction of the Primary Woody Biomass definition and its related use limitations and financial support withdrawal would:

  1. Jeopardise energy security of local decarbonised supply: Such definition includes large shares of residues and by-products from forests that have been sustainably used for renewable energy production for decades. These residues and by-products are removed as a consequence of harvesting to supply wood for pulp and sawmills to allow for the planting of new trees. Moreover, thinning ensures sufficient growth and carbon capture of the remaining wood stock. Thus, they have no other practical and economical application than displacing often-imported fossil fuels. Given the criticality of biomass in boilers and CHPs, the Parliament’s approach would lead to further supply shortages for the coming heating seasons, worsening the current gas-supply stress as well as damaging power supply during the time it is most needed.
  2. Neither prevent undue forest management nor provide further safeguards for protected areas: As explicitly acknowledged by the JRC[1], restrictions on primary woody biomass for energy use will not be effective in preventing undue forest management practices. The basis for safeguarding sustainable forest management should be that existing REDII sustainability criteria[2], which already require protection of protected areas, are properly enforced in national laws and regulations. Further, a distinction between primary/secondary woody biomass would not alter harvesting practices as working forests are managed according to demand from other forest products facilities, such as sawmills. The energy industry only uses residues or by-products with substantially lower commercial value than roundwood. This material will continue to be produced and discarded if it cannot be used for sustainable energy and to displace fossil fuels.
  3. Delay the transition to climate neutrality: Biomass plays a key role in the energy transition as recognised by the IPCC, the IEA, the National Climate Strategies[3] and the EU’s 2030 Climate Plan Impact assessment. It is an important source of renewables, providing reliable and dispatchable energy, complementing variable wind and solar generation. Primary woody biomass residues that are not utilized for energy purposes are otherwise crushed and left to decompose on the forest floor. This causes CO2 emissions but yields no energy. By contrast, using these residues, within the thresholds beneficial for biodiversity, in the energy sector provides a significant climate benefit because fossil fuels, and related emissions, can be displaced.
  4. Increase energy prices: Financial support is key to the use of biomass, as it is for most forms of renewable energy, in many Member States. The restrictions on primary woody biomass would arbitrarily reduce available feedstocks that could receive financial support. As such generators will converge on secondary biomass, causing a significant price increase which will compound the current energy security crisis. It will also increase imports from outside the EU, including from countries with less strict sustainability criteria. This would not just be limited to large generators but also spill over into the heat market causing further price increases.

Eurelectric Recommendations

Having assessed the consequences of the Parliament’s approach, we recommend the Council to:

  • Reject the Parliament’s introduction of a definition for “primary woody biomass”
  • Reject the Parliament’s proposal to cap its use in the renewable energy mix and electricity and heat production and to withdraw all financial support.

Instead, as an alternative, negotiators could address the impact on biodiversity & climate by:

  • Enforcing the fulfilment of sustainability requirements via strong national forestry schemes or certification systems validated by independent third-party auditors.

Concerns about cascading and possible market distortions of financial support to bioenergy are best addressed by:

  • Making the cascading principle operational at national level in line with the proposals put forward by the Council in their General Approach. The new Renewable Energy Directive could elevate its legal status by enshrining the principle in article (3).

We trust that our concerns and suggestions will be given due consideration and remain available to discuss them further in a meeting with your offices.



[1] Joint Research Centre (JRC), 2021: The use of woody biomass for energy production in the EU. Accessible here

[2] Art 29.6 (a)(iii) &(b)(iii) of REDII already includes requirements for biomass sourcing to protect areas designated for nature protection purposes.

[3] At Member State level, for example France foresees an increase of 40-60% in the production of RES heat by 2028 (between 219-247 TWh in 2028 compared to 150 TWh in 2018). French PPE (Programmation Pluriannuelle de l’Energie).

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