CEPI is of the opinion that sustainability criteria for the sustainable sourcing and conversion of solid biomass should address primarily potentially adverse effects of a strong increase of the use of solid biomass for energy including from imports. Since the 2020 renewable energy target ultimately aims at reducing greenhouse gas emissions, solid biomass criteria should primarily be carbon related and include efficiency principles.
Regarding forest management, the criteria should apply irrespective of the final use of the wood. They should be limited to the criteria set out below, since further detailed forest management criteria would conflict with national forest policies, go beyond the intention to ensure carbon neutrality and ignore the specificities of Sustainable Forest Management in the different parts of Europe.
In addition to the carbon and forest management related sustainability criteria applying to the sourcing of biomass, energy conversion of biomass eligible for support should be subject to efficiency principles to ensure the positive substitution effect of carbon neutral biomass.
Solid biomass shall be taken into account for the purposes of the Renewable Energy Directive/eligible for support only if it fulfils the following:
1. Biomass sourcing
1.1 Carbon sustainability:
Forest biomass shall come from countries with mandatory LULUCF accounting. If biomass is procured from non-LULUCF accounting countries, credible proof has to be given that the harvesting rate in this country does not exceed 100% and the biomass does not come from land conversion. Where there is overharvesting at the country level, the operator has to give sufficient proof that there is no overharvesting at the relevant regional level of the biomass origin
1.2 Forest management
Forest biomass shall come from legal sources. Verification: Compliance with the provisions of the EU Timber Regulation EC/995/2010.
Forest biomass shall come from forests that are managed in accordance with the principles and criteria of sustainable forest management as defined by the Helsinki Resolution H1: General Guidelines for the Sustainable Management of Forests in Europe.
Outside of Europe they shall at least correspond to the criteria or guidelines for sustainable forest management as adopted under the respective international and regional initiatives (ITTO, Montreal Process, Tarapoto Process, UNEP/FAO Dry-Zone Africa Initiative).
2. Biomass conversion
2.1 Greenhouse Gas Savings criterion:
The GHG saving should be at least 50% (60% from 2018) compared to the national fossil fuel based generation of electricity and heating and cooling.
In addition to the sustainability criteria on carbon and forest management, installations eligible for support for the use of solid biomass for energy generation should be subject to efficiency principles to ensure the positive substitution effect of carbon neutral biomass.
Resource efficiency principles:
Heat and electricity based on solid and gaseous biomass should be produced at an overall efficiency of at least 70% (lower for small installations (e.g. < 1 MW) or where CHP cannot be applied). Member states should not support but further even avoid the use of biomass in coal plants with the current low efficiencies. Supporting co-firing of biomass in coal plants at low efficiencies is an environmentally harmful subsidy.
Cascading approach to forest raw material principles:
The development of the energy use of biomass can only be considered in the light of an application of a "cascading approach", a principle that aims at promoting, whenever it applies, the most efficient use of natural resources with a view to optimize the creation of value, ideally firstly for food, then products and finally for energy. A supply policy for forest biomass – which ideally should also be allocated some support funding - must include this cascading use principle and allow all needs to be met.
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