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TO: Members of the European Parliament ITRE Committee
Subject: Alignment of the revision of the Renewable Energy Directive with the Circular Economy Policies
Dear Members of the ITRE Committee,
Ahead of the report of the ITRE committee on the revision of the EU Renewable Energy Directive (RED II), the undersigned organisations, representing plastic and paper recyclers and zero waste associations around Europe, would like to bring to your attention our concerns as regards to inconsistency of the Commission’s proposal in RED II with the Circular Economy policies and the EU’s climate policy agenda.
This is due to the consideration of the biomass fraction of mixed municipal solid waste as a source of renewable energy when it is actually burning thanks to other materials (e.g. plastics and paper). Member States are consequently allowed to support various forms of energy generation from waste, to meet targets set under the RED II. These schemes which support waste-to-energy generation from mixed municipal waste, run counter to the EU’s transition to a low-carbon and circular economy, furthermore this would work to:
1. Undermine the Waste Hierarchy and the Circular Economy policies
Financial support for waste-to-energy from mixed municipal waste subverts one of the cornerstones of the EU waste policy – the waste hierarchy -, which establishes an order of priority in waste prevention and management i.e. prevention, preparation for re-use, recycling, other recovery (energy recovery), and disposal1. Waste is therefore meant to be firstly prevented, then prepared for reuse and, finally, recycled. Conversely, the RED II classifies it as a source of ‘renewable energy’ and allows renewable energy support schemes that conflict with the waste hierarchy by encouraging waste-to-energy processes, which is the second least desirable option of the waste hierarchy.
The effect so far has been a clear distortion of the market whereby investment in waste infrastructure and operation costs are organised on the basis of subsidies for the extraction of energy from waste instead of sound environmental and economic performance of the best waste management option. As a result, several European countries e.g. Denmark have overinvested in energy-from-waste plants whilst underinvesting in recycling facilities.
2. Undermine the Communication on Waste-to-Energy in the Circular Economy
The RED II also contradicts the Commission’s recent Communication on the Role of Waste-to-Energy in the Circular Economy which states that public financing of waste management, whether national or at EU level, should be consistent with the waste hierarchy and Member States should phase-out public support for the recovery of energy from mixed waste in line with the separate collection obligations and more ambitious EU recycling targets proposed in the legislative proposal on Circular Economy2.
3. Undermine the EU’s Climate Policy Agenda
The Commission’s proposal also undermines the EU’s climate agenda by supporting energy generation from mixed municipal waste, which is never solely composed of biogenic carbon. Much of the calorific value from waste-to-energy processes from mixed waste (incineration, pyrolosis or gasification) comes from the treatment of fossil carbon based materials such as plastics. For example, a typical waste incineration facility has a carbon intensity of approximately 600 kg CO2 eq. per MWh of electricity. This compares with a figure of 380 kg CO2 per MWh of electricity at an efficient natural gas power station using Combined Cycle Gas Turbine technology3.
Moreover, the monitoring of the amount of the proportion of organic waste compared to the amount of fossil-based waste in municipal mixed waste is both logistically and technologically difficult. It’s often assumed that the proportion is 50% - even if industrial and commercial waste is frequently included in the mix of waste entering a waste-to-energy facility. Given the heterogeneity of waste and the great differences from plant to plant, this percentage is neither constant nor reliable, which supports the evidence that much of the so-called renewable energy from waste-to-energy comes in fact from incinerating fossil carbon based materials.
The undersigned organisations therefore urge the members of the ITRE Committee to align the Commission’s proposal for a revised Renewable Energy Directive with the circular economy policies by explicitly excluding primes of subsidies for waste-to-energy generation from the mixed municipal solid waste.
On behalf of signatories
Joan Marc Simon
ZWE Executive Director
Janek Vahk, Development and Policy Coordinator, Zero Waste Europe: firstname.lastname@example.org
Ulrich Leberle, Raw Materials Director, The Confederation of European Paper Industries: email@example.com
Antonino Furfari, Managing Director, Plastics Recyclers Europe: firstname.lastname@example.org
CEPI position on the Commission proposal for a regulation on the inclusion of GHG emissions and removals from LULUCF into the 2030 climate and energy framework
The main goal for the European pulp and paper industry in the debate on climate change and forestry is to work on a policy framework enabling the long term sustainable management of European forests. This is in line with the conclusions of chapter 9 of the 4th Assessment Report of the International Panel on Climate Change (IPCC): “In the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks, while producing an annual sustained yield of timber, fibre or energy from the forest, will generate the largest sustained mitigation benefit.”
The main concern of the European pulp and paper industry is that proposals for the inclusion of GHG emissions and removals from LULUCF focus on the 2030 horizon and forest sequestration. Meanwhile the potential of the other aspects of sustainable forest management such as the absorption of carbon by more dynamic forest management and storage and substitution of wood products replacing fossil based ones would not be sufficiently recognised and harvesting levels would be reduced.
The European pulp and paper industry is a key contributor to the bioeconomy. It uses wood from sustainably managed forests to produce renewable and recyclable products which substitute more carbon intentive products.. In addition, the European pulp and paper industry produces bioenergy with highly efficient combined heat and power generation. Further increasing the efficiency of the wood use, the industry is developing new products based on wood to grow the bioeconomy and even more substitute fossil based materials. The mitigation potential could be further improved by further supporting the growth of forests, dynamic forestry and the mobilisation of wood, the use of wood-based products, high value added products, the cascading use principle and strengthening innovation in new bio-based products.
Accurately accounting the emissions/removals from the sector is crucial to demonstrate that European forests and the use of its products have a positive contribution to climate change, as forests absorb carbon from the atmosphere and sequester it. Harvested wood products store carbon and substitute fossil based products. Along the chain, wood, harvesting residues and industrial residues are also used to produce bioenergy substituting fossil fuels. (Replacing fossil fuels by bioenergy is an interim target on the way to bio-based value chains creating high value added from products, materials and fuels.)
In the last decades, forests in Europe have been growing both in surface and in growing stock. Looking ahead, Chapter 9 of the 4th Assessment Report of the IPCC states: “In the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks, while producing an annual sustained yield of timber, fibre or energy from the forest, will generate the largest sustained mitgigation benefit. Most mitigation activities require up-front investment with benefits and co-benefits typically accruing for many years to decades. The combined effects of reduced deforestation and degradation, afforestation, forest management, agro-forestry and bioenergy have the potential to increase from the present to 2030 and beyond”. The combined climate change mitigation effect should be maximised. Therefore disproportionate measures on one of these elements should be avoided.
In this context CEPI and its members welcome the recognition of forests and forest products in the EU’s new climate and energy policy framework 2020-2030 and the inclusion of the land use, land use change and forestry sector in the framework.
Even though the proposal is on a 10 year period, it should incentivise the long term carbon benefits of forests and the bio-economy. The inclusion should not lead to an optimisation for the 2020 to 2030 period. In the long term, Europe will need more wood products.
The regulation should provide a framework incentivising Member States to promote a forest management, which increases the capacity of its forests to take carbon out of the atmosphere and at the same time store it in products that substitute fossil products.
The Commission proposal includes several positive principles:
Emissions from the land use sector are reported when harvesting takes place. Carbon emissions should be accounted once. Emissions from the combustion of biomass should therefore accounted as zero to avoid double counting. This also ensures the climate effect of the wood use is allocated to the country in which the trees are harvested.
Harvested Wood Products (HWP) are recognised as carbon pools contributing to the mitigation efforts. We believe this is a very important element of the framework, as HWP provide a mitigation potential well below the 2020-2030 period.
Flexibility between LULUCF and the effort sharing sector is limited to afforestation. This gives Member States with potential for afforestation the possibility to use this abandoned land for afforestation. The potential for afforestation is varying strongly between Member States. However, we believe it is not necessary to limit this flexibility to 280 million tons of CO2. There should not be flexibility between LULUCF and effort sharing sector for forest management.
We believe that the Commission should continue work towards international progress in carbon accounting and encourage other world regions to account for their emissions from LULUCF, particularly countries from which the EU is sourcing wood for bioenergy and products. A credible and though workable scheme in Europe could facilitate the uptaking of similar initiatives in other world regions. Such bottom-up approach has proven successful in the Paris agreement.
Finally we welcome the fact that the proposal is directed to the Member States rather than smaller entities. This ensures the contribution from forestry is regarded upon in landscape approaches and with long time frames.
The Commission proposal contains provisions to be improved:
The framework should be comprehensive and as flexible as possible to further allow Member States to develop policies based on their national conditions.
Forest management reference levels should be set on the basis of long timeframes in order to better reflect trends and responses to climate change policies and measures already in force. These timeframes should enable reference levels to emphasise the impact of most recent policy instruments affecting forest resources, forest management and use of forest products in the country.
The setting of projections based on reference levels has to be credible and transparent and should be based on subsidiarity in forest related issues. The European Commission’s role should be focused on ensuring harmonised country established reference levels and on ensuring credibility and transparency rather than a centralised recalculation on those national elements.
The criteria for the establishment of forest reference levels should be reviewed and better focused on carbon relevant criteria. Biodiversity conservation is already addressed in specific EU and national legislation and this should be reflected in policy.
The option chosen by the Commission is based on the no-debit rule. CEPI believes the no-debit rule is crucial in the LULUCF proposal to demonstrate that the forest sector acts as a sink. However, we believe that Member States demonstrating they harvest less than the net annual increment should not be sanctioned.
SÃO PAULO – The theme of the 2017 United Nations International Day of Forests is Forests and Energy. The International Council of Forest and Paper Associations (ICFPA) of which CEPI is a member is proud to represent the global forest products industry, which plays an important role in contributing to the production of renewable energy. While manufacturing its products from wood sourced from sustainably managed forests, the industry reduces dependence on fossil fuels. It uses by wood manufacturing residuals, byproducts and forest residues – collectively known as biomass – to produce efficiently much of the energy required for its operations and provides heat to local communities as well as to electrify the grid.
According to the international carbon accounting principle, when combusted for energy, biomass does not contribute to global climate change as growing trees sequester carbon from the atmosphere via photosynthesis. The ICFPA reiterates the carbon neutrality of biomass in a policy statement here
“The sustainable management of forestry including the efficient use of biomass for energy is key to achieving global climate change commitments and are core principles in making the low-carbon bioeconomy a reality in Europe.” says Sylvain Lhôte, Director General at CEPI
According to the United Nations Food and Agriculture Organization, wood provides the world with roughly 40 percent of current global renewable energy supply – more than solar, hydroelectric or wind power. Sustainably-managed forests have a key role in meeting several United Nations Sustainable Development Goals and providing solutions for a growing green economy.
To increase the role of forests in providing renewable energy and to reduce the use of fossil fuels, the forest-based industry invests in technological innovation and sustainably-managed forests to improve yields and practices. In the past ten years, the energy share of biomass and other renewable fuels has increased ten percentage points from 53 to 63 percent.
The ICFPA represents more than 30 national and regional forest and paper associations around the world, including CEPI
For more information about the sustainability of the global forest and paper industry, visit icfpa.org.
The European Parliament has today opted to follow the ambitious lead set by Environment committee’s vote on the Circular Economy package in January this year.
The most important outcome from today’s vote is that MEPs moved in favour of one single calculation method that enshrines real and comparable recycling rates both in and for Europe.
“Today, the European Parliament has fully grasped the opportunity to make the Circular Economy work for Europe by enabling industry and local authorities to better target where investment needs to take place” says CEPI Director General Sylvain Lhôte
CEPI recognises that the new recycling targets are ambitious while providing new opportunities in terms of improving quality.
“For an industry where over half of our feedstock comes from paper for recycling, the Parliament’s approach means greater use of raw materials whilst putting the emphasis on quality” says CEPI Raw Materials Director Ulrich Leberle
The vote to encourage the use of bio-based packaging also demonstrates the importance of a Circular Economy that builds upon Europe’s wealth of renewable resources while accelerating the transition towards a low-carbon economy.
Finally the continued assertion of the separate collection of paper is viewed by the European paper and board industry as a means to bridge ambitious targets with higher quality recycling.
CEPI together with other partners in the European paper value chain will shortly publish its updated European Declaration on Paper Recycling where it addresses its commitment to the new targets.
The Circular Economy is one of the core elements necessary to achieving industry transformation in Europe as outlined in our ‘Investment Roadmap’ towards a low-carbon bioeconomy. Check out our alignment matrix for the full picture.
For more information, please contact Ulrich Leberle at email@example.com or by phone at (+32) 2 627 49 23
For press related enquiries, please contact Ben Kennard at firstname.lastname@example.org or by phone at (+32) 487 39 21 82
In view of the European Commission's publication of its Winter Energy package, the European paper industry has compiled a position paper outlining its stance on key aspects of the proposal. Here are our key messages:
Deliverables expected by “Clean energy for all Europeans” package, as a whole:
• Promotion of cost-competitive energy prices
• Consistency between policy measures
• Stability and predictability of the regulatory framework
Deliverables expected by specific legislative proposals:
• Allowing for market-based prices to show real value of electricity
• RES generators should participate in the markets in the same way as all other generators
• Subsidies to RES-E should not be allowed to distort wood supply markets
• Security of electricity supply to energy intensive industry must be secured
• Demand flexibility should be voluntary and rewarded
• The benefits of CHP should be recognised (efficiency, cost effective, energy security, resource efficiency)
• EU should not create more bureaucracy or official bodies / authorities
Energy Union Governance
• No to a binding cap on energy consumption impeding industrial growth
• Increased mobilisation of forest biomass is essential in reaching the 2030 renewable energy target
• Need for a real focus on industrial competitiveness
• Reduction of administrative burden for business needs to be prioritised
• Need to avoid/minimise policy conflicts and overlaps
• The directive should not set a binding EU cap on energy consumption
• Member States should be allowed to set their own indicative targets
• Costs and potentials varies across Member States: there is no one-size-fits-all energy savings trajectory
• Equal footing between obligation schemes and alternative measures needs to be preserved
• Cogeneration to remain at the core of the Energy Efficiency Directive
• Support schemes should not distort wood markets and should stimulate supply of wood
• Opening up to national schemes to cross-border participation in electricity markets should lead to more market integration, not to harmonised subsidies
• Guarantees of origin should remain as trade description, not to be used as subsidies
• There is no “one size fits all” in heating and cooling: focus should be on flexibility and cost-efficiency
• Emission reduction in transport should cost-efficiently drive renewable energies in transport (RES-T) integration into the market while not resulting in transportation costs increased
• Our industry is an emerging producer of RES-T solutions mainly from wastes and residues, such as advanced biofuels, biogas, excess electricity from bio-based pulp and paper mills...
• Bureaucracy and costs should be avoided when implementing sustainability criteria
The full position paper can be consulted via the link below.