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Bioenergy Europe

Bioenergy Europe is a non-profit organization promoting sustainable bioenergy production and use in the EU.

Lobbying Activity

Bioenergy Europe demands alignment with existing EU energy directives

5 Dec 2025
Topic — The EU is reviewing taxonomy rules to update and simplify technical screening criteria.
Message — Bioenergy Europe calls for the taxonomy to stay aligned with current renewable energy rules to maintain stability. They request the removal of restrictive wording that prevents projects using multiple fuel types from qualifying. They also oppose stricter greenhouse gas limits and new regulations on wood use.12
Why — Regulatory stability would lower financing costs and prevent projects from becoming stranded assets.34
Impact — Taxpayers could face higher bills if public funding must replace discouraged private investment.5
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Meeting with Ingeborg Ter Laak (Member of the European Parliament)

2 Dec 2025 · Bioenergy and BECCS

Meeting with Yannis Maniatis (Member of the European Parliament)

1 Dec 2025 · Introductory Meeting

Meeting with Peter Liese (Member of the European Parliament)

5 Nov 2025 · Austausch

Bioenergy Europe urges recognition of renewable heat in energy security

13 Oct 2025
Topic — Revised EU energy security framework for gas and electricity supply.
Message — The organization requests that renewable heat be explicitly integrated into risk preparedness and resilience planning. They want bioenergy recognized as essential infrastructure alongside gas and electricity, with support for heating replacement programmes and hybrid renewable systems.12
Why — This would elevate bioenergy's status in EU policy and secure funding for their industry.34
Impact — Gas suppliers lose market share as bioenergy replaces fossil fuel heating systems.56
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Bioenergy Europe urges bioenergy priority in EU heating decarbonisation

6 Oct 2025
Topic — EU strategy to accelerate decarbonisation of heating and cooling across households, industry and businesses.
Message — The organization requests that bioenergy be prioritized as a dispatchable renewable heat source that complements electrification. They call for EU funding to replace outdated heating systems with renewables, a definitive phase-out of fossil fuel subsidies, and redirected financial flows toward renewable heating solutions.1234
Why — This would secure bioenergy's market position and increase demand for their members' products and services.56
Impact — Heat pump manufacturers face reduced market share if bioenergy receives prioritized policy support and funding.78
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Meeting with Robert Nuij (Head of Unit Energy)

29 Sept 2025 · Exchange of views on the review of the ecodesign and energy labelling legislation on solid fuel local space heaters

Meeting with Robert Nuij (Head of Unit Energy)

29 Sept 2025 · Exchange of views on the review of the ecodesign and energy labelling legislation on solid fuel local space heaters

Bioenergy Europe seeks flexibility in carbon removal certification rules

22 Sept 2025
Topic — EU regulation certifying permanent carbon dioxide removal through DACCS, BioCCS and biochar.
Message — The organization requests alignment with existing renewable energy rules, flexibility in biomass feedstock choices for biochar projects, and removal of economic viability tests for new facilities. They argue current requirements create unnecessary barriers and inconsistencies with established sustainability frameworks.123
Why — This would reduce regulatory barriers and enable larger-scale deployment of bioenergy carbon removal projects.45
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Bioenergy Europe urges explicit carbon removal targets in 2040 climate framework

16 Sept 2025
Topic — Amendment to EU Climate Law establishing 2040 greenhouse gas reduction target.
Message — The organization requests explicit recognition of permanent carbon removals in the 2040 framework through separate targets for gross emission reductions, LULUCF, and permanent CDR. They call for integration of removals in the EU ETS from 2028 and development of a dedicated European CDR Strategy by 2026.12
Why — This would create market certainty for their carbon removal technologies and secure funding streams.34
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Meeting with Elisabetta Gualmini (Member of the European Parliament)

15 Jul 2025 · ITRE Committee

Bioenergy Europe Urges Inclusion of Carbon Removals in ETS

7 Jul 2025
Topic — Review of the EU emissions trading system and the market stability reserve.
Message — Bioenergy Europe requests including permanent carbon removals like BioCCS in the ETS under a like-for-like principle. They also oppose lowering the 20 MW threshold to prevent administrative burdens on small operators.123
Why — This would create stable investment signals for bioenergy technologies and prevent high compliance costs.45
Impact — Sellers of temporary removal units from forestry or soil are excluded from the ETS market.6
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Bioenergy Europe urges full integration of bioenergy in new strategy

20 Jun 2025
Topic — This consultation aims to develop a circular, regenerative, and competitive bioeconomy strategy for Europe.
Message — Bioenergy should be a key pillar of the upcoming strategy to reduce fossil dependency. The Commission must respect regional differences in energy needs and launch a mobilization program with targeted incentives to unleash untapped biomass potential.123
Why — The organization would benefit from increased biomass availability and financial support for local collection hubs.45
Impact — Fossil fuel suppliers would lose market share as biogenic carbon is prioritized for industrial processes.6
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Meeting with Morten Løkkegaard (Member of the European Parliament)

16 Jun 2025 · Bioenergy

Meeting with Filip Turek (Member of the European Parliament)

14 May 2025 · Updates on the Eco-design draft proposal for SFBs and LSHs

Bioenergy Europe calls for excluding agricultural prunings and industrial residues

13 May 2025
Topic — The European Commission is consulting on amending the list of products covered by the Deforestation Regulation.
Message — The organization requests excluding wood from permanent crops like olive trees and vineyards from the regulation's scope. They also seek to exempt all waste materials and residues defined by renewable energy rules, arguing geolocation for these is impractical.123
Why — The proposed changes would significantly reduce administrative costs and compliance burdens for biomass producers and sawmills.45
Impact — Environmental groups lose supply chain transparency as excluding residues makes it harder to verify wood origins.6
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Bioenergy Europe urges financial perspective for building energy standards

7 May 2025
Topic — The Commission is revising the methodology for calculating cost-optimal energy performance requirements for buildings.
Message — The organization advocates for a financial perspective rather than a macroeconomic one when establishing national benchmarks. They also demand that the methodology recognize on-site biomass combustion as renewable energy produced on-site to ensure legislative consistency.12
Why — Bioenergy remains competitive by excluding health and environmental costs from the performance calculations.3
Impact — Public health groups lose if air pollution costs are omitted from national energy benchmarks.4
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Meeting with Beatrice Timgren (Member of the European Parliament)

30 Apr 2025 · Ecodesign regulation for Solid Fuel Boilers

Meeting with Asger Christensen (Member of the European Parliament)

10 Apr 2025 · Bioenergy Europe

Meeting with Filip Turek (Member of the European Parliament)

9 Apr 2025 · Ecodesign draft proposal for SFBs and LSHs

Meeting with César Luena (Member of the European Parliament)

7 Apr 2025 · EUDR Simplification and Inclusion in the Omnibus Package

Meeting with Niels Ladefoged (null Energy)

3 Apr 2025 · The work on regulating solid fuel appliances.

Meeting with Christine Singer (Member of the European Parliament)

20 Mar 2025 · Bioenergy

Meeting with Norbert Lins (Member of the European Parliament)

12 Mar 2025 · Clean Industrial Deal

Meeting with András Gyürk (Member of the European Parliament)

12 Mar 2025 · Biomass, bioenergy

Meeting with Jeannette Baljeu (Member of the European Parliament)

11 Mar 2025 · Bioenergy

Meeting with Silvia Sardone (Member of the European Parliament, Committee chair) and ERION COMPLIANCE ORGANIZATION S.C.A R.L.

11 Mar 2025 · ENVI COMMITTEE

Meeting with Aura Salla (Member of the European Parliament)

11 Mar 2025 · Clean Industrial Deal and bioenergy

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Bioenergy Europe, the leading association representing the solid biomass sector in Europe, welcomes the opportunity to provide feedback on the draft Delegated Act amending Regulation (EU) 2024/1735. While we support the overall objectives of the Act, we are concerned about the omission of key final products and components under the "biomass technologies" sub-category. Biomass technologies, including bioenergy solutions, are well-established, commercially available, and play a vital role in decarbonization and industrial competitiveness. Despite this, the draft Delegated Act fails to recognize biomass-based final products and components, creating an imbalance in the regulatory framework. Biomass heating plants, CHP facilities, and advanced conversion technologies such as gasification and pyrolysis are already widely deployed across Europe and are integral to the EUs clean energy transition. Excluding these solutions disregards their proven contribution and places them at a disadvantage compared to other renewable technologies. Furthermore, while the draft Act includes syngas-to-SAF conversion, it does not acknowledge hydrogen production from biomass gasification, even though both rely on the same technological principles. This inconsistency weakens the regulatory framework and undermines the potential of biomass-based hydrogen, despite its strong sustainability credentials. Given Europe's expertise in syngas and bio-based hydrogen technologies, we strongly recommend its inclusion within the "Hydrogen Technologies" category. Another critical omission is the lack of recognition for carbon capture and removal (CDR) technologies. Negative emissions solutions, such as bioenergy with carbon capture and storage (BECCS) and biochar production, are essential for achieving net-zero targets. We urge the inclusion of key CDR componentssuch as CO storage tanks, liquefaction systems, and process control unitsto provide regulatory clarity and encourage investment in these essential technologies. To ensure a fair and inclusive regulatory framework, we call on the European Commission to: Explicitly include biomass-based final products and components in the Delegated Act. Recognize hydrogen production from biomass gasification as a key net-zero technology. Adopt a more comprehensive approach to CDR technologies, incorporating essential components and alternative carbon storage pathways. We urge the Commission to carefully consider our detailed analysis and recommendations, which are outlined in the attached position paper. Bioenergy Europe remains available for further discussions to help shape a more balanced and effective regulatory framework.
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Meeting with Radan Kanev (Member of the European Parliament)

20 Feb 2025 · Supporting bioenergy

Meeting with Vytenis Povilas Andriukaitis (Member of the European Parliament) and Cancer Patients Europe

29 Jan 2025 · Exchange of views

Meeting with Aurelijus Veryga (Member of the European Parliament)

15 Jan 2025 · Sustainability and Energy Security Goals and Issues of Renewable Energy

Meeting with Andrea Wechsler (Member of the European Parliament) and BASF SE and

10 Dec 2024 · EU Energy and industry policy

Meeting with Stefan Köhler (Member of the European Parliament) and Fornybar Norge (Renewables Norway)

10 Dec 2024 · Politischer Austausch

Meeting with Vytenis Povilas Andriukaitis (Member of the European Parliament)

2 Oct 2024 · Bioenergy

Meeting with Irene Tinagli (Member of the European Parliament)

2 Oct 2024 · Introductory meeting

Meeting with Giorgio Gori (Member of the European Parliament) and Associazione Italiana per l’Information and Communication Technology

2 Oct 2024 · Presentation of priorities

Meeting with Nicolás González Casares (Member of the European Parliament) and European Environmental Bureau and

25 Sept 2024 · Energy transition

Meeting with Isabella Tovaglieri (Member of the European Parliament)

19 Sept 2024 · La bioenergia in Italia

Meeting with Vytenis Povilas Andriukaitis (Member of the European Parliament)

19 Sept 2024 · EU Policy

Meeting with András Tivadar Kulja (Member of the European Parliament)

18 Sept 2024 · Bioenergy and green transition

Meeting with Sofie Eriksson (Member of the European Parliament)

18 Sept 2024 · Bioenergins klimatpåverkan och roll i energimixen

Meeting with Eszter Lakos (Member of the European Parliament)

18 Sept 2024 · Energy sector

Meeting with Giorgio Gori (Member of the European Parliament) and smartEn Smart Energy Europe and Open Fiber

17 Sept 2024 · Presentation of priorities

Bioenergy Europe seeks transition period for biomass sustainability rules

29 Jul 2024
Topic — This consultation updates European rules for monitoring and reporting greenhouse gas emissions under the ETS.
Message — The group requests including specific exemptions for remote regions and a certification transition period. They also want guidelines on how to prove these criteria are not applicable.123
Why — A transition period would prevent regulatory disruption and ensure continuous energy access for remote regions.45
Impact — Environmental groups lose from the delayed application of updated sustainability and greenhouse gas criteria.6
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Bioenergy Europe urges realistic LULUCF targets and technical carbon sinks

11 Jul 2024
Topic — This consultation evaluates the effectiveness of the LULUCF Regulation since its 2018 entry.
Message — The organization calls for science-based targets that respect long forestry cycles and increased flexibility against natural disturbances. They advocate for separate emission reduction targets and the inclusion of technical carbon removal methods like BECCS.12
Why — This would lower regulatory pressure on foresters and secure timber supply for bioenergy production.34
Impact — Agriculture and industry lose the ability to use forest sinks to offset their own emissions.5
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Bioenergy Europe rejects merging solid fuel and heat pump labels

20 Dec 2023
Topic — The Commission is reviewing energy labelling and efficiency rules for solid fuel boilers.
Message — The group opposes merging labels for heat pumps and boilers. They argue the biomass label factor must be retained to ensure renewable comparisons.12
Why — This would prevent regulatory costs from making biomass boilers more expensive for consumers.3
Impact — Consumers lose detailed information required to make specific technology-based purchasing decisions.4
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Bioenergy Europe urges fair efficiency rules for biomass heaters

12 Dec 2023
Topic — The European Commission is reviewing ecodesign requirements for solid fuel local space heaters.
Message — Bioenergy Europe requests a new efficiency calculation that accounts for renewability to ensure fair comparisons. They recommend harmonizing testing methods with industry standards and avoiding mandatory third-party certifications. The group warns that setting emission limits for partial loads would be premature.123
Why — This would lower compliance costs and protect the market competitiveness of biomass heaters.45
Impact — Environmental advocates lose more rigorous pollution monitoring and stricter device certification requirements.67
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Bioenergy Europe urges equal treatment for carbon removal technologies

31 Aug 2023
Topic — EU strategy for deploying carbon capture, utilisation and storage to achieve 2050 climate neutrality.
Message — The organization requests clear definitions distinguishing CCS, CCU, and CDR technologies. They want significant financial incentives including subsidies and a compliance market for permanent carbon removals. They demand equal assessment of all CDR technologies without singling out BECCS for negative scrutiny.1234
Why — This would make bioenergy with carbon capture financially viable and secure their industry's role.56
Impact — Environmental groups lose stricter scrutiny of bioenergy sustainability risks and biomass sourcing standards.7
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Bioenergy Europe seeks strategic status in Net Zero Industry Act

26 Jun 2023
Topic — Legislative proposal to scale up manufacturing of clean technologies within the European Union.
Message — Bioenergy Europe demands including solid bioenergy and carbon capture as strategic technologies. They also recommend lowering technology readiness levels to accelerate commercial adoption.12
Why — Strategic status would grant the industry faster permitting and preferential access to funding.3
Impact — Fossil fuel sectors would lose the exclusive benefits currently tilted toward standard carbon capture.4
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Bioenergy Europe urges regulatory stability for 2040 climate targets

22 Jun 2023
Topic — This consultation establishes an EU 2040 climate target to achieve neutrality by 2050.
Message — The organization calls for keeping biomass sustainability criteria unchanged to ensure a stable regulatory framework. They demand binding EU targets for carbon removals and a clear phase-out strategy for fossil fuels.123
Why — Maintaining current rules would reduce administrative burdens and protect the profitability of bioenergy investments.45
Impact — Fossil fuel companies would lose significant financial assistance and market access through subsidy bans.67
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Meeting with Kadri Simson (Commissioner) and

20 Jun 2023 · Presentation of new report on smart electrification.

Meeting with Clara Aguilera (Member of the European Parliament)

5 Jun 2023 · Carbon Removal Certification Framework

Meeting with Günther Sidl (Member of the European Parliament)

24 May 2023 · Certification Framework for Carbon Removals; staff level

Bioenergy Europe urges permanent removal status for biochar technology

22 Mar 2023
Topic — EU regulation establishing certification framework for carbon removals to scale sustainable solutions.
Message — The organization requests clarification of permanence criteria to include biochar and other novel removal technologies, not just those under the CCS Directive. They seek harmonization with existing bioenergy sustainability requirements in RED to minimize administrative burdens.123
Why — This would allow bioenergy producers to certify biochar as permanent removal and avoid conflicting requirements.45
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Response to Energy labelling requirements for local space heaters (review)

12 Aug 2022

The Commission, as part of the energy labelling regulations revision, has recently proposed to merge, into a single scale, the energy labelling of all generators which, as a function, offer space heating (Lot 10 and Lot 20). The proposal also provides for a classification scale (A-G) shared by all technologies. While supporting the Commission's intention to update the existing label, as well as to remove less efficient products from the market, we oppose the merger of these two lots and strongly oppose the creation of a single classification for energy labelling of local space heaters (LSH) and air-to-air heat pumps (AAHP) as proposed by the Commission. In this context, we have strong concerns regarding this development because: 1. LSH and AAHP are incomparable products since they serve distinct functions and use different fuels (e.g. renewable wood or electricity). Previous legislation was opposed to the having the same energy labelling scales; in recital 5 of Regulation (EU) No 2015/1186 it argues that “as the typical use and therefore also energy consumption of local space heaters is different to that of other space heating products being regulated, this Regulation should introduce a labelling scale different to that of other space heating products.” 2. Merging different energy labels will decrease the granularity of information and hamper the ability of consumers to make informed purchasing decisions. 3. The energy efficiency labels fail to adequately consider important factors including seasonal variations impacting AAHP and the efficiency of electricity generation. Energy losses present in the electricity production process are ignored for the purposes of calculating which option is more efficient. This can lead to a perverse incentive where electricity production from solid fuels to then produce heat is promoted over the direct generation of heat in LSHs without transmission losses even when these options are in reality less efficient given our current electricity mix. 4. A common scheme would limit innovation and investment in both AAHP and LSH as the new merged label would chain product groups to 2-3 classes making R&D investments less effective in gaining market advantage. By pushing certain product groups towards higher energy label ratings, these manufactures will be less incentivised to innovate as they are already at the top of the energy label. Conversely, the manufacturers of the product group pushed to the bottom of the scale will lose their motivation to continue investing in improved efficiency, since even the most advanced and energy-efficient products would be relegated to the bottom of the scale. 5. Combining the labelling systems ignores energy security concerns. The energy crisis that we are experiencing right now should be an example of how a complex and crucial sector should not be based primarily on a single supply chain. Supply chain independence does not only apply to fuels or energy, but also to raw materials and technologies. 6. Environmental aspects are not adequately considered. 7. The consumer study does not prove that the introduction of a combined scale will result in any average energy efficiency gain. The shortcomings of this study included that: A. It does not consider technical constraints as not all the European consumers could install a AAHP or LSH. B. It does not consider regulatory constraints as several European countries have national or regional law that constrain which appliances can be installed. C. It assumes that consumers had access to all energy sources. D. It assumes that consumers had access to all technologies. E. It minimizes the role of the consumer’s evaluation of the aesthetics of the product. F. Hypothetical willingness to pay evaluation in a consumer study leads to strong “hypothetical bias” as participants regularly overstate their real willingness to pay by 50%. For further elaboration on these points, please see our attached position paper.
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Bioenergy Europe demands biomass inclusion in renewable zones

26 Jul 2022
Topic — EU guidance to streamline permitting and speed up renewable energy project deployment.
Message — The group demands that biomass plants be included in designated renewable zones. They argue all sustainable technologies deserve equal treatment to meet energy targets. Policy makers should also provide more staff to process permit applications.123
Why — This allows biomass projects to avoid discrimination and speeds up administrative approvals.45
Impact — Consumers may face continued reliance on fossil gas for flexible power generation.6
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Bioenergy Europe urges including construction wood waste as biomass

23 Jun 2022
Topic — The consultation seeks to update EU industrial emissions rules for better environmental protection.
Message — Bioenergy Europe requests deleting the reference to wood waste from construction and demolition. They argue untreated wood should be recognized as biomass for energy recovery purposes.12
Why — Including this wood waste would expand available fuel sources for sustainable bioenergy production.3
Impact — Waste disposal businesses could lose volume as more wood moves toward energy recovery.4
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Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur) and US Industrial Pellet Association

11 May 2022 · RED

Bioenergy Europe Urges EU Carbon Removal Framework with Economic Incentives

2 May 2022
Topic — EU regulatory framework for certifying carbon removals to scale sustainable solutions.
Message — The organization requests a robust certification mechanism with economic incentives for negative emission technologies, including technology-neutral approaches and multiple approved methodologies. They emphasize the urgency of immediate implementation to meet 2050 climate targets.12
Why — This would create revenue-generating markets to support and upscale bioenergy carbon capture technologies.34
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Meeting with Susana Solís Pérez (Member of the European Parliament)

14 Feb 2022 · Ensuring that sustainable bioenergy is a key pillar in delivering a carbon neutral Europe.

Meeting with Mikuláš Peksa (Member of the European Parliament)

9 Feb 2022 · RED III

Meeting with Maria da Graça Carvalho (Member of the European Parliament)

4 Feb 2022 · bionergy, renewable energies directive, biomass installations, biofuels

Meeting with Tom Vandenkendelaere (Member of the European Parliament, Rapporteur for opinion)

20 Jan 2022 · renewable energy, presentation of sector

Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur)

19 Jan 2022 · The Energy Performance of Buildings Directive

Meeting with Christophe Grudler (Member of the European Parliament, Shadow rapporteur)

14 Jan 2022 · Révision de RED II (biomass)

Meeting with Jérémy Decerle (Member of the European Parliament)

12 Jan 2022 · Impact du Fit-for-55 sur la bioénergie

Meeting with Asger Christensen (Member of the European Parliament)

12 Jan 2022 · Bioenergy

Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

11 Jan 2022

Bioenergy Europe welcomes this initiative and the publication of the draft implementing regulation amending Article 38 of the Monitoring and Reporting Implementing Regulation (EU) 2018/2066. Considering that relevant delegated and implementing acts of the Renewable Energy Directive (REDII) are considerably delayed, most Member States have been struggling to transpose crucial provisions of REDII related to sustainability and GHG emissions savings criteria, such as the development of national certification systems. Such a situation creates a practical problem for both national administrations and stakeholders using biomass, which in most cases must rely on voluntary certification schemes (despite the lack of an official list of such schemes accepted by the European Commission). Concerning the Monitoring and Reporting Implementing Regulation, Art. 38.2 states that only sustainable biomass can retain a 'zero emissions factor'. When both sustainability and adequate GHG emissions savings criteria cannot be proven due to the lack of a national certification system, CO2 emissions from the combustion of such biomass is counted as if it was coming from fossil fuels, necessitating the surrendering of ETS allowances from the facility operator. It has far-reaching consequences as it poses a risk that entities who opted for clean energy sources like bioenergy will be penalised for using it, due to administrative reasons. It would de facto disincentivise the use of biomass, slowing down the pace of decarbonisation and undermining the investment capacity. Therefore, it is a matter of urgency to rapidly adopt the proposed implementing regulation and restore legal certainty for the users of biomass. Bioenergy Europe encourages the EC to prioritize work on this file, and exhaustively communicate with relevant national regulatory authorities and market participants, which seek guidance on the accounting of emissions from biomass within EU ETS and the new legislative framework set by REDII. Lack of clarity in this regard undermines the competitiveness of biomass technologies and is contradictory to the intention of the legislator who explicitly stated that sustainable biomass should retain the zero emissions factorwithin the proposed revision of the EU ETS Directive. Bioenergy Europe fully supports the proposed amendment of Art. 38 of the Monitoring and Reporting Implementing Regulation: ‘Member States may consider as fulfilled the sustainability and greenhouse gas emissions saving criteria referred to in that paragraph for biofuels, bioliquids, and biomass fuels used for combustion from 1 January 2022 to 31 December 2022.’ We believe the derogation should be further strengthened by replacing 'may consider' with 'shall consider’. This wording would guarantee a robust, efficient, and harmonised implementation of the EU law within all Member States and decrease the risk of fragmentation of the single market. Bioenergy Europe also supports the objective of the alignment of the bioenergy policies with other environmental objectives and fair access to the biomass raw material market - as mentioned in recital 3. Crucial for this process will be the strengthening of the sustainability and GHG emissions savings criteria proposed by the revised Renewable Energy Directive. As the current situation confirms, the capacity of Member States and market operators to adjust to the new framework should be realistically assessed and acknowledged. One of the aforementioned principles in the recital is the ‘cascading use of biomass’. In this regard, Bioenergy Europe considers that the EU regulation of cascading would not be the right policy tool to prevent biomass market distortions from happening (as recognised in 2018). Consequently, Member States could benefit more from an updated cascading guidance document.
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Meeting with Salvatore De Meo (Member of the European Parliament)

13 Dec 2021 · Riscaldamento rinnovabile nel Fit for 55

Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

Bioenergy Europe welcomes the European Commission’s proposal for the recast of the Energy Efficiency Directive (EED). The draft shows a renewed interest towards heat decarbonisation, listing concrete measures to further promote the uptake of renewable heat solutions such as sustainable biomass. The proposal also encourages member States to take action to raise awareness on renewable sources and provide technical and financial advice to increase their further uptake. All this, whilst looking at energy poverty issues, especially regarding the heating sector and pushing for an urgent need to modernise Europe’s ageing heating stock. The Commission is moving in the right direction, but some key points still need to be improved. The new energy efficiency target is an important step towards the 2050 goal, and this must be mutually reinforced with further RES penetration. Hence, member states should not only “consider” renewables in their decarbonisation strategies, but actively promote RE sources and renewable energy communities. Furthermore, the combination of efficiency and renewables should be optimised to provide the final users with sustainable options while maintaining lower overall heating costs.This can be easily done by replacing old and inefficient heating systems (often operating on fossil energy) with modern renewable ones. Phasing out fossil energy and shifting towards renewable technologies like sustainable bioheat contributes to the three targets at the same time: reduce GHG emissions and improve air quality; increase efficiency and support a higher RES share. Given that the EED and the Renewable Energy Directive (REDIII) are so intimately linked, notably around the issue of the heating and cooling sector, it stands to reason that a new definition of “renewable heat” must be developed and specifically mention solutions such as sustainable biomass, geothermal and solar heat in Article 2. In EU households, heating needs (space heating and domestic hot water production) account for 79% of total final energy use. Considering that almost 80% of this heat is still fuelled with fossil energy, the new benchmark presented in article 21 should focus on renewable heat sources, such as bioenergy, instead of renewables in general. Accordingly, the upcoming Energy Performance of Building Directive (EPBD) must be harmonised with the EED provisions and further support them. In this context, local heat planning can be an extremely important resources for local authorities: provisions to support heat planning at local level must become mandatory for entities above 50k inhabitants, and at the same time support must be granted to smaller realities especially in rural areas. This will be pivotal to further increase renewable heat penetration. The new EED must strongly promote fuel switch towards renewable sources both in residential and district heating systems. In this context, a better definition of “efficient district heating” will be needed since the aim of Article 24 is to increase the share of renewables in district heating networks. Therefore, natural gas cannot have a preferential role in the recast and renewable heat must be the preferred solution for new and substantially refurbished systems. The definition should allow the use of waste-based residues that are still available after the sorting process with due regard to the waste hierarchy as set out in Article 4 of Directive 2008/98/EC. Finally, it is relevant to note that the primary energy factor (PEF) has a direct influence on other key legislations, such as Regulation (EU) 2017/1369 on energy labelling and Directive 2009/125/EC establishing a framework for ecodesign requirements for energy-related products. Given that the energy mix and scenarios can vary significantly among Member States a revision of the PEF every 4 year may be not needed and even too disruptive at national level.
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Response to Revision of the Energy Tax Directive

16 Nov 2021

Achieving the ambitious climate and energy targets envisaged within the European Green Deal and the improvement of the internal market functioning require revision of the Energy Taxation Directive (ETD) which has not undergone any changes since 2003. A robust fiscal framework for energy products can substantially contribute to the EU's 2030 energy targets and increase the effectiveness of other decarbonisation policies. Crucially, the revised ETD must better reflect the environmental impact of polluting energy products and remove subsidies for fossil fuels. The new ETD, thanks to the well-designed system of minimal excise rates, should incentivise customers to purchase the least carbon-intensive source of the energy and to promote renewable energy production and investment as intended in the Renewable Energy Directive. It is therefore crucial that sustainable biomass fuels are exempted from the scope of the proposed legal act. One of the challenges of the reform of the carbon pricing system proposed within the Fit for 55 package is to design it in a socially acceptable way. The extension of the carbon pricing via the EU ETS system on fossil fuels used in the building and transport sector, combined with higher excise rates, phased-out subsidies, and tax exemption for these fuels, will inevitably increase price levels. The impact of such changes will be mostly felt by vulnerable customers. Sustainable biomass fuels are the most affordable replacement of fossil fuels in the heating sector. These solutions are cost-competitive and easy to scale up. As bioenergy is locally sourced, the development of its value chain facilitates the creation of local jobs as well as sets regional and rural development objectives. Therefore, to offset the prospective rise of prices in the heating sector, the use of sustainable bioenergy fuels should be promoted and incentivised. Further, it is counterproductive that minimum tax rates are envisaged to be imposed on sustainable biomass fuels – the only renewable energy fuel undergoing a thorough sustainability assessment. It would slow down the transition from fossil fuels and lead to unnecessarily high costs for end users. Moreover, the new tax would inevitably impose an administrative burden on small and mid-scale enterprises supplying these fuels which will send a bad signal to all market players involved. Imposing a flat common rate for all biomass fuels will particularly disincentivise consuming the lowest-priced fuels produced from different types of residues and wastes, which will thus undermine the circular use of such products. The use of these fuels for energy has considerable environmental advantages, and there is a risk that due to decreased competitiveness, some of these fuels will end up at landfills and decay without producing any substitution benefit. There will be a similar effect for harvesting residues with a high cost for collection and transport, particularly in remote locations. Moreover, the impact assessment related to the legislative proposal misses the analysis of market effects of minimal rates for biofuels and certain solid wood products, which will spill over in the increasing costs within the transport and heating sectors. As a result, such measures may lead to unintended market consequences: considering the objectives and side-effects of the EU ETS reform, they may worsen the price impact on the most vulnerable customers. The purpose of the ETD is to minimise unfair competition on a common market in favour of fossil fuels thanks to unproportionally low tax burdens they have benefitted from so far. This is mainly a problem concerning fossil fuels. For bioenergy, there is scarce evidence that tax exemption or reductions have been used to distort competition on the market. On the contrary, measures undermining the competitiveness of such products will result in slowing down the decarbonisation pace in sectors that are already lagging behind.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

The achievement of the more ambitious GHG emission reductions target, eventually leading to reaching climate neutrality by 2050, necessitates an adjustment of the EU ETS functioning. The 'polluter pays' principle should be at the core of the EU energy and climate policies, while covering all emissions of fossil fuel combustion and integrating them in the EU ETS, would present important benefits in terms of effectiveness and harmonization of the European carbon pricing system. Therefore, Bioenergy Europe supports key aspects of the proposed reform, both regarding the extension of the scope of the EU ETS, particularly to transport and building sectors, as well as higher Linear Reduction Factor, leading to the faster pace of reductions, compatible with delivering 61% of reductions by 2030, in the covered sectors. Crucially, Bioenergy Europe welcomes that the 'zero-emission factor' for sustainable biomass is maintained in the system. 'Zero-emission factor' provides assets using sustainable bioenergy with the competitive edge necessary to replace more polluting technologies in hard-to-decarbonize sectors like industry or buildings. Faster and deeper decarbonization of aforementioned sectors necessitate broader use of bioenergy technologies. This is particularly true given the recent upward fluctuations of the energy prices combined with high carbon intensity of electricity in the many Member States, has shown to what extent electrification cannot be seen as a silver bullet that guarantees deep decarbonization of the EU economy. For Bioenergy Europe the key dimension of the reform refers to the extension of the carbon pricing system to the building sector. Currently, the EU ETS covers only 30% of buildings emissions from heating. It is estimated that approximately 132 million of small installations below 20 MW of thermal input using fossil fuels, are outside the EU ETS. In addition, fossil fuels used in small installations often enjoy preferential tax treatment, notably decreasing any incentive effect for the necessary technological switch of heating appliances. In this regard, the revision of the Energy Taxation Directive is a needed complementary to a broadened EU ETS element to successfully phase out fossil fuels subsidies in the EU. It should be noted also, that MS should have the right and possibility to impose taxes on CO2, which are higher than EU ETS allowances price. Bioenergy Europe supports such extensions nevertheless, we underline that the carbon price on heating fuels should be considered as a complementary instrument to other existing tools, not a sole driver of the decarbonization. It should act as an incentive for governments to implement ambitious renovation programs and supportive fuel switch policies. The uniform EU-wide price on heating emissions is a socially regressive policy that will have a stronger impact on lowest-income households. In the absence of social compensation policies, the lowest-income households will be the most affected since they spend a higher share of their revenue on energy bills. Therefore, measures supporting vulnerable consumers like Climate Action Social Fund, are crucial to guarantee the social acceptability of the reform. Hence, the Fund should have sufficient budget and be phased in early enough to help protect the most vulnerable from the compounded effect of higher energy prices and carbon pricing Prospective increase of the EU ETS allowance prices leading to higher revenues allows for the increase of of budgets of the EU financing instrument – Modernization and Innovation Funds. These tools could support the implementation of the projects that facilitate the faster decarbonization of the EU economy, provided that they support a wide array of technologies according to the technology neutrality principle, and in particular in the heating sector.
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Response to Land use, land use change and forestry – review of EU rules

8 Nov 2021

Bioenergy Europe welcomes the opportunity to provide feedback on the proposed LULUCF regulation. Overall, Bioenergy Europe is concerned that the current draft is neither suited to support the transition to a bioeconomy nor to phase out the use of fossil materials and energy. The proposal would put restrictions on the use of forest and wood products and counteract the climate and renewable energy targets of the green deal. The decision in the new LULUCF regulation to abandon the complex and cumbersome FRL system is a positive development as the new regulation will create a more efficient and streamlined framework. Although the shift to this new accounting system is positive, there are some unresolved issues remaining. First, the removal target of 310 million tons of CO2 equivalent in 2030 seems to have been established in an arbitrary manner as a political goal, to achieve climate neutrality in a new AFOLU sector in 2035 rather than having a clear methodology with science-based targets. This target should consider the ability to remove more carbon and the most cost-effective methods to improve and protect biodiversity. If the target is set too high, it would require forests to be set aside and exclude the possibility of active forest management. Although this absence could increase the amount of biomass in forests in the short-term, it would also make the forest more vulnerable to shocks such as fires and pest outbreaks, as well as reduce long-term carbon sequestration potential. Second, the linear trajectories identified for Member States from 2026 to 2029 are very steep. Many of the interventions that can increase removals are slow processes that cannot be scaled up at the level proposed by this regulation. If achieving these levels requires reducing harvesting, it could have dramatic negative impacts on the entire bioeconomy, which relies on raw material inputs from forests to substitute fossil-based and energy-intensive resources. This risks not only creating higher prices and shortages, but also layoffs and the loss of livelihoods, especially in rural areas. Therefore, it is important that Member States are more involved in determining what contributions are appropriate. Third, these removal targets do not consider the age structure of the forests nor the future development of the forests in terms of adaptation to climate change. Forest management decisions occur over long-time frames of 80-100 years and because trees absorb carbon at different rates at different ages, the age structure of a forest determines what removals are achievable and when the forest reaches carbon saturation. Therefore, it is necessary to consider age structure as well as adaptations to climate change to have a nuanced understanding of the future carbon sink possibilities. Fourth, although it is plausible that creating a new AFOLU land sector could increase synergies, it is unclear how this will end up working in practice. If agricultural emissions are not significantly reduced, then even the current sustainable harvest level may be insufficient to achieve climate neutrality in 2035. It is unclear how or why the target of a carbon-neutral unified land sector in 2035, 15 years before the rest of the economy, can be reached. Additionally, it does not make sense that forests should be responsible for absorbing the emissions of other sectors due to their lack of abatement. Given the different practices and legislation governing LULUCF and agriculture, any merger must be carefully considered. Finally, Bioenergy Europe welcomes the changes made to Article 9 to broaden it to "carbon sequestering products" as it is important to consider other carbon sequestering products such as biochar. Biochar has considerable permanent CO2 storage potential and should be included as a carbon sequestering product. Given the absence of IPCC guidelines on biochar, the EU Commission should advocate for the creation of GHG reporting guidelines for biochar at the UNFCC.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European farmers and

8 Nov 2021 · Forest based industries

Bioenergy Europe urges EU support for carbon capture technology

7 Oct 2021
Topic — EU initiative to certify carbon removals and promote carbon farming practices.
Message — The organization requests financial and regulatory incentives for carbon removal technologies, particularly bioenergy with carbon capture and storage. They want clear definitions of key terms like permanence of storage and inclusion of biochar as a carbon pool.123
Why — This would support their core business of bioenergy production while positioning BECCS as essential climate technology.45
Impact — Advocates of nature-based solutions may lose priority as funding shifts toward technological carbon removal.67
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Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson) and

22 Sept 2021 · Draft Climate, Energy and Environmental State aid Guidelines.

Response to European Bioeconomy Policy: Stocktaking and future developments

31 Aug 2021

To achieve the ambitious climate goals, it will be important not only to reform the EU’s energy sector, but also to encourage material substitution: shifting away from harmful fossil-based products to sustainably produced bio-based ones. Bioenergy plays an essential role in promoting and supporting a sustainable bioeconomy by creating a use for low quality feedstocks that would otherwise be discarded, utilizing waste and residues, and recovering energy from bioeconomy products at their end-of-life. To maximize the impact that the bioeconomy can have, it is important that the EU ensure it fully utilizes its biogenic resources and avoids placing new restrictions limiting its sustainable growth. When adapting the recommendations on Bioeconomy Policy into future legislation, the EU should endeavour to support small and medium-sized actors who may have limited ability and administrative capacity to develop detailed sourcing policies or robust data verification. SMEs and rural actors often have a more limited ability to demonstrate compliance with EU regulations. The initiative also aims to support a method for prioritizing the uses of biomass, namely through the cascading principle. The cascading use of biomass is an important principle which is already in practice through market mechanisms which ensures that the highest quality wood goes to the highest-value, and longest-lived products. When developing the European Bioeconomy Policy, it will be important that the cascading principle is not proposed in such a ridged way that it undermines the efficiency of the bioeconomy and ignores local heterogenous factors. If there is a formal system, any classification of a feedstock acceptable for bioenergy under the cascading principle should apply for a minimum of five years to create a stable market. An exceedingly rigid interpretation could depress the bioeconomy, stagnate innovation, and nullify the synergies between the bioeconomy and bioenergy. As both the largest source of renewable energy and the largest indigenous energy source in the EU, bioenergy fulfils an essential function in securing energy independence and enabling a green transition with the potential for BECCS which can even result in negative emissions. A sustainable bioeconomy policy will be crucial to ensure that the EU can simultaneously meet its environmental targets, maintain its economic competitiveness, and promote social equity. Bioenergy, and the bioeconomy more broadly, are most active in rural areas where they are an important driver of development and employment. According to the JRC , the European bioeconomy has a turnover of 2 trillion euros and employs more than 17 million of people. Bioenergy also enhances the energy security of these areas and reduces energy poverty. Any application of the Bioeconomy Policy needs a holistic consideration of sustainability to ensure that the social element is not overlooked. The promotion of new, diverse, and local value chains can bring added value of the bioeconomy especially in rural areas. The development of this sector will ensure economic and social improvements while protecting biodiversity and the local environment. Promoting innovation will be essential for ensuring future resilience as circular bioeconomy value chains allow new opportunities for jobs and growth. This can further support sustainable forestry practices reducing risks of forest fires as well as farmers and rural communities in adapting to climate change, diversifying their revenues, and protecting their crops from adverse weather events. Finally, it will be important that the Bioeconomy Policy recognizes the subsidiarity principle as Member States have heterogenous bio-resources, different climate conditions, and regional specialization. Moreover, it will be important that future EU proposals respect Member States’ competence in legislating forest policy and their right to preserve their own unique national traditions and practices.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

15 Jul 2021

Bioenergy Europe welcomes the opportunity to comment on the Draft Implementing Act on the rules to verify sustainability and greenhouse gas emissions savings criteria and low indirect land-use change-risk criteria. The document includes several deviations from the Renewable Energy Directive text and could result in excessive administrative burden for market operators. For this reason, the bioenergy sector recommends the inclusion of the targeted amendments attached to this reply. These amendments include: a uniform 12 months period of time to achieve mass balance for all actors in Article 19, removing the retroactive nature of the current dates established in Article 28, and the revision of Annex IV. Bioenergy Europe supports the swift adoption of a workable text, providing voluntary schemes and economic operators with the necessary guidance for demonstrating compliance with the sustainability criteria.
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Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson)

24 Jun 2021 · Fit for 55 package; Review of the REDII criteria, in particular the sustainability criteria for solid biomass.

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

24 Jun 2021 · RED Revision

Response to Guidance on REDII forest biomass sustainability criteria

26 Apr 2021

Bioenergy Europe acknowledges the importance of the guidance to enable robust and harmonised implementation of the new sustainability criteria for forest biomass by Member States and economic operators. Coherence in the interpretation of the measures and timeliness in transposition and implementation are paramount in preventing the arising of barriers to the internal market. The sector regrets the delay in publication of such draft guidance, that has generated further uncertainty in the operators. The preparedness of the system and tools to certify compliance will be paramount to its functioning. To avoid repeating the negative experience of liquid biofuels, through the shortages and consequent slow-down in 2011, the European Commission should, in cooperation with national authorities, prevent any regulatory gaps between the demand being generated for sustainable biomass, and its (certified) availability on the market. We emphasize that this is not a sustainability issue, as our members comply with all EU and member state regulatory requirements. Rather, this is an issue of the mechanisms and systems our members can use to demonstrate compliance to national authorities. While looking forward to the European Commission recognition of voluntary schemes and publication of standards, the European Bioenergy sector broadly welcomes the content of the present draft and the opportunity to comment it. However, Bioenergy Europe notes that this draft regulation in its current formulation, stretches the boundaries of the criteria as laid down in the Renewable Energy Directive, by adopting several recommendations from the 2021 Joint Research Centre report on woody biomass. Bioenergy Europe’s position is that the inclusion of these criteria should be avoided at this stage. This is in line with JRC’s own recommendations for a swift implementation of RED II for managing sustainability risk from biomass sourcing. Introducing at the very last stage additional requirements that are unfamiliar to member states and economic operators could jeopardize the implementation. Bioenergy Europe believes that the inclusion of a set of targeted recommendations would improve the document and ease operationalisation of sustainability criteria, please consider full commentary in the attached document.
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Meeting with Mikuláš Peksa (Member of the European Parliament)

23 Mar 2021 · Renewable Energy Directive

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Bioenergy Europe supports the highest level of ambition in the decarbonisation of building sector in order to achieve carbon neutrality by 2050. Consistently with this position, we have supported the increased use of renewable energy in the public consultations following the presentation of the European Green Deal as the main pathway to decarbonise domestic heating and cooling. The first round of national energy and climate plans showed an insufficient level of ambition from the Member States to decarbonise heating and cooling sector, which accounts for half of energy consumption in the European Union. Renewable Energy Directive (RED)’s article 23 target of a 1.3 percentage point increase in renewable heating and cooling is insufficient to achieve climate neutrality as 13 points increase in 10 years will not get existing stock anywhere close to carbon neutrality in 2050. Residential sector accounts for 21% of EU energy consumption and the building sector needs a stable framework after the presentation of the long-term renovation strategy by Member States and the need for national governments to increase their NECP’s heating targets. As in the RED public consultation, we consider higher targets for renewable heating and cooling shall be accompanied by non-binding measures in the Energy Performance of Buildings Directive (EPBD, option 2 of the inception impact assessment). While heating and cooling represent half of the EU energy consumption, just 22% of this is renewable, more than 80% provided by bioenergy. Currently more than 66 million of households are heated with bioenergy. Biomass has also been recognised as the only cost competitive technology in the European Commission’s report on Competitiveness of the heating and cooling industry and services, having the potential to further reduce utilities bills to consumers, addressing energy poverty. There is no technology bottleneck to increase RES in buildings with many solutions using solar, biomass or ground/ambient heat, sometimes combined. Biomass equipments are now more and more efficient with very low emissions, ready to replace old appliances. What we need is a strong signal from EU, going down to the country and local levels. In this sense, Bioenergy Europe believes the EPBD can be a bridge to achieve the new renewable targets through a smooth implementation of the strategies until 2026 where further measure should be taken to be sure the new building stock is 100% renewable.
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Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

Bioenergy Europe welcomes the opportunity to comment on the Draft Delegated Regulation supplementing Regulation (EU) 2020/852 and Annexes. The Taxonomy Regulation can be a key enabler for scaling up sustainable investments and achieve EU’s raised climate ambition by accelerating the transition. For this legislation to deliver and become a useful tool to trigger sustainable investments, the requirements listed in the delegated regulation and annexes must be scientifically rigorous, actionable and based on existing metrics. Bioenergy Europe welcomes the closer alignment of the Annexes with the provisions of the Renewable Energy Directive 2018/2001. While the Taxonomy Regulation does not mandate any investments into economic activities meeting its criteria, it creates a barometer revealing the degree of sustainability for each sector. We are also conscious the Commission intends to integrate the Taxonomy into other areas, such as State Aid and the Recovery and Resilience Facility. If Taxonomy requirements are not based on existing metrics they could constitute an unnecessarily punitive labeling of perfectly sustainable economic activities. In these respects, Bioenergy Europe calls on the European Commission to consider introducing a set of modifications to the criteria (Annex I and II) covering the bioenergy sector and value chain. The full list of proposed amendments and justification is in the attached document.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Bioenergy Europe welcomes the opportunity to comment on the Roadmap on the Amendment of the EU Emissions Trading System. It is a matter of great urgency to strengthen the current ETS by aligning the emissions ceiling with the increased target of at least 55% GHG reduction for 2030, and to further pathways towards carbon neutrality by 2050. Bioenergy Europe would like to highlight that this revision may serve not only to increase the pace of decarbonisation, but to introduce other substantial changes improving functioning of the EU ETS. Nevertheless, the Market Stability Reserve outtake rate of 24% has contributed effectively to the reduction of the oversupply. The rate should be maintained throughout the phase and hedging bands adjusted downwards to reflect the demand throughout the phase. In line with forecasts presented in the Integrated National Energy and Climate Plans and in the Impact assessment of the European Commission’s Communication on Stepping up Europe's 2030 Climate Ambition, bioenergy will play important role in delivering EU climate ambitions by 2030 and 2050. Reaching the EU’s updated 2030 climate goals will require efforts from across the entire economy, not just the energy sector or biggest industrial emitters. According to the Communication on Stepping up Europe's 2030 Climate Ambition, within the identified five policy scenarios to deliver 2030 target, four include the extensions of the EU ETS system on road transport and buildings. Currently, the EU ETS covers only 30% of emissions from heating. It is estimated that approximately 132 million of small installations below 20 MW of thermal input using fossil fuels, are outside the EU ETS. Fossil fuels used in small installations often enjoy preferential tax treatment, notably decreasing the incentive for technological switch. Similarly, decarbonisation pace of road transport sector responsible for 70% of all transport emissions in the EU is not sufficient. It requires introduction of the mix of policy measures addressing road transport, among which carbon pricing would support the transition towards use of clean technologies, including sustainable biofuels. Covering all emissions of fossil fuel combustion and integrating them in the EU ETS, would present important benefits in terms of effectiveness and harmonization. Nevertheless, it should not constraint Member States willing to introduce even higher carbon pricing on a top of the EU ETS price in the heating sector via other tools such as carbon taxation. For instance, in Sweden, the ETS carbon price level stands only for a quarter of the current carbon dioxide tax. Cost efficiency, credibility, and low administrative burden should be a guiding principle for the design of different options. Adequate incentives supporting the development of negative emission solutions: such as biochar; carbon farming and Bioenergy with Carbon Dioxide Capture Use and Storage should be put in place Lack of incentives for removals is an essential barrier in the framework of the EU climate policies for their development. It is important to send the right signal to the industry and potential investors. Therefore, the analysis and the legislative proposals of the EU ETS due in June 2021 should make clear the overall view of the Commission on progress with carbon removal in the EU (in particular to the forthcoming carbon removal certification framework, which the Commission has announced for 2023). Finally, the EU ETS establishes that the use of sustainable biomass is zero-rated. This principle has been incorrectly challenged. Biomass growth removes carbon dioxide from the atmosphere and stores it in soils, trees and other plants. When managed and harvested in a sustainable way, biomass reduces fossil fuel emissions to the atmosphere by directly displacing oil, coal and natural gas use. The biogenic carbon cycle is recognized by IPCC and global climate experts and it is at the basis of biomass zero-rating.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

Bioenergy Europe welcomes the initiative to align LULUCF rules with the new 2030 climate target, paving the way for carbon neutrality by 2050. While the mention of carbon farming initiative within the Farm to Fork Strategy and the certification of carbon removals part of the Circular Economy Action Plan are relevant, the roadmap does not divulge details on the main drivers for land use: the Common Agricultural Policy. In this sense, the recent publication of the European Commission flagship eco-schemes and the preparation of the Strategic Plans by Member States represent a unique opportunity to increase the role of sustainable forest management and bioeconomy in substituting fossil fuels such as coal and material and increasing carbon sequestration Sustainable forest management represents an essential tool to address most of the causes of the decrease in forests’ sequestration potential reflected in the LULUCF accounting variations such as droughts, forest fires and pest outbreaks (significantly bark beetle), by increasing the resilience, adaptation to climate change and ultimately GHG absorption capacity of the forests. The positive trend in member states with highly developed managed forestry proves that this strategy is best for the climate. High growth rate and high harvesting rate has also led to constant growth of the standing stock in the forests. The sustainability of biomass used to produce energy in Europe is guaranteed by strict, harmonised, Union-wide criteria for biofuels, bioliquids and biomass fuels introduced in RED II, coming into force in 2021. These criteria, together with risk-based forestry certification schemes, underpin biomass sustainability. Contrary to what is stated in the roadmap, there has not been a correlation between an increased use of biomass and pressure on the forest, on the contrary both trends have been simultaneous. In the case of bioenergy, it represents a stable percentage of 20% of total harvests since 2000 while bioenergy consumption in Europe has doubled since then. Looking at the evolution of the wood removals by type of end-use, it is clear that bioenergy is not a driving force behind forest harvesting and that the sector increasingly uses residues from forest-based industries. Considering the low-value streams used for energy, such as tops, branches and thinnings, an increased harvest for bioenergy would have hardly any impact on sequestration because this wood would degrade rather quickly in the forest rather than replacing fossil fuels. Based on the three options presented, to strengthen the flexibility with the Effort Sharing Regulation (ESR) (option 2) seems the more suited considering the objective mentioned in the roadmap of taking into account the potential impacts of the COVID-19 crisis and recovery. This option has been recognised at the impact assessment of the 2030 Climate Target Plan to be a strong driver for moderating overall compliance costs of achieving 55% GHG. Moreover, the opportunity remains to provide improved incentives for the EU sink to be enhanced, with a view to achieving net-zero GHG by 2050 and this outcome will ultimately depend on how the ESR review currently in place will take place and consistency between all the policies currently in place, but particularly between LULUCF and ESR.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

Air quality is an issue that particularly concerns the bioenergy sector, being the reason why we actively provide solutions to tackle it. Based on years of R&D, new biomass plants and appliances are offering a solution to the problem thanks to better performing technologies that are limiting particulate matter (PM) emissions, CO, NOx and other pollutants. In addition to Flue gas cleaning, today digital performance optimisation solutions can also be used for minimising emissions. Further, today digital solutions allow to follow emissions in detail and real-time instead of periodically. Some of the emission components are already monitored in great detail this way as a common practice. Modern bioenergy plants such as combined heat and power (CHP) as well as smaller modern heating equipment with wood pellets have already low emissions, this is particularly the case for large installations and industrial uses covered by the Industrial Emissions and Medium Combustion Plan Directives. As regards the smaller domestic heating appliances, Bioenergy Europe supports the update or replacement of the heating stock, which now lies at the very heart of the SWITCH4AIR campaign. According to a European Commission-financed study, almost 30% of the EU heating appliances were installed before 1992 and only 40% after 2002, with a very similar age structure for biomass appliances. This is relevant because emissions from one old open fire stove is equivalent to the emissions of 278 of the most modern Ecodesign-compliant appliances. In that line, a CERIC study has estimated that the replacement of old appliances by new ones together with the use of high-quality feedstock can reduce PM 2.5 emissions up to 90% . This renovation must go hand-by-hand with the increase in public awareness of the air pollution problem and the role of buildings within its scope: 1. Construction professionals, installers, maintenance staff and chimney sweepers are at the first line of the renovation wave and their upskilling as part of the Skills Agenda and the upcoming Pact for Skills should also cover air quality together with renewable energy sources. 2. Existing or planned initiatives should address this gap and include training and upskilling for energy professionals. Moreover, certification systems for these workers should be promoted. 3. Scrappage schemes for exchanging old bioenergy appliances for modern ones should be supported by the Renovation Wave Initiative. 4. Emissions can be easily avoided by educating end-users to properly use their wood stoves. 5. The quality of the fuel used for heating also plays an important role in limiting emissions. Certified biomass like with the ENplus quality certification system for wood pellets, offers a secure and reliable quality of pellets with the best output. Regarding soil and water protection, and besides the clear environmental advantage of utilisation of residues and biological by-products, perennial plant species such as Miscanthus or willows have been linked with environmental advantages, such as reducing the leaching and run-off of nutrients and pesticides into ground/surface waters. Miscanthus and willow can also be used for phytomanagement and phytoremediation of damaged soil by removing pollutants such as heavy metals and creating added value. Bioenergy Europe welcomes the effort to address the pollution problem in an integrated way and as such, wants to highlight that the development of the bio-based economy can be highly beneficial to reduce pollution from the extraction, processing and transport of raw materials. Bioenergy is part a truly sustainable concept in which not only environmental aspects are addressed but also the creation of jobs and economic activities. Europe needs such multiple approaches to succeed in our Green Deal and bioenergy is part of the solution.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Bioenergy Europe welcomes the European Commission initiative evaluating the possible revision of the Renewable Energy Directive ((EU) 2018/2001). The achievement of the carbon-neutrality objective by 2050 will require a prompt adjustment of the mid-term climate and energy objectives measures. For this reason, Bioenergy Europe welcomes the 2030 Climate Plans commitment to increase deployment of renewables to achieve higher GHG emissions savings. However, the sector regrets the non-technical wording describing sustainable bioenergy contribution in such Communication, as it provides a misleading image of the sector. Indeed, the term ‘whole trees’ already misused in the biodiversity strategy, remains troubling. ‘Whole tree’ is an arbitrary designation that does not relate to a particular forest product or grade of wood, rather it appeals to emotions. Energy wood is produced as part of forest management, but not driving harvesting. Bioenergy improves the economic viability of low range timber, and wood decayed or damaged as a result of disturbances (wild-fires; pests, and storms). The review of elements of the Renewable Energy Directive to achieve alignment to the EGD initiatives should be discussed by legislators, following a thorough evaluation of the existing measures and requirements. While realignment of energy and climate targets are necessary, a full-fledged revision of the Directive at this stage seems not to be neither needed nor justified. Further, such revision could easily create uncertainty. Among the policy options briefly outlined by the European Commission’s roadmap, Bioenergy Europe would favour Option 5 entailing a smart combination of Options 2, 3 and 4e market-actors need long-term perspective to promote investments and ensure further renewable energy uptake. Bioenergy Europe's full reply is the attached document.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Bioenergy Europe welcomes the opportunity to contribute to the public consultation on the revision of the Energy Efficiency Directive. Bioenergy Europe believes that to reach the 2050 decarbonisation targets, 2030 climate and energy objectives must be revised. The penetration of renewables in the heating sector must be prioritised by 2030 to decarbonise Europe’s building stock. Further energy savings will allow to reduce reliance on fossil fuels and increase the share of renewable over the total energy mix. Among the policy options presented by the inception impact assessment, Bioenergy Europe supports Option 3 (revision of the EED) combined with Option 2 (non-regulatory measures). The energy efficiency target is currently not non-binding: countries have struggled in implementing the necessary measures to its achievement. Further efforts will be required to achieve the carbon neutrality by 2050 and align the economic recovery with a decrease in energy consumption: • Bioenergy Europe believes the energy efficiency target should be adjusted to be in line with the carbon neutrality target. The achievement of higher energy savings depends also on the modernisation of the heating stock. Further penetration of renewables in this sector is key to ensure its decarbonisation. Currently, the heating and cooling sector accounts for almost half of EU’s energy consumption, including space heating for buildings and process heat for industry Considering the potential of higher energy efficiency for renewable heating, the target for renewable heating and cooling must be increased to achieve at least 50% of the final heat to be renewable by 2030. • Awaiting the European Commission assessment, preliminary analysis suggests that the final NECPs might still have the potential to further increase energy efficiency. The potential gap between the nationally set targets and the common target of 32.5% by 2030 must be filled to achieve carbon neutrality by 2050. The renovation wave initiative and Next Generation EU implementation must be aligned with this objective. • Targeted measures are necessary to foster a prompt fuel switch and adopt renewable heating solutions such as bioenergy or privilege renewable based highly efficient cogeneration technologies. For this purpose, the definition of efficient heating and cooling and efficient district heating and cooling must be narrowed to promote renewable sources. Adequate financial incentives and specific trainings to reskill installers and raise awareness will be exceptionally important in this case. Bioenergy represents the perfect ally for energy efficiency, as it rises the renewable energy penetration in the heating and cooling sector in a cost-efficient manner, promoting additionally circular and bio-based economy.
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Response to Long term vision for rural areas

27 Aug 2020

Bioenergy Europe welcomes the European Commission exercise to define the role and future of rural areas. Rural areas are at the heart of Europe’s competitiveness in key sectors, such as food and energy and are fundamental for bioenergy industry’s contribution to climate action. According to the JRC, between 2015 and 2030 about 11 % of agricultural land in the EU faces a high potential risk of abandonment due to biophysical land suitability, farm structure and agricultural viability, population and regional specifics. Societal and regulatory changes are affecting the current value change of agricultural industry, implying changes in the economic structure of rural areas: • Ageing of the European population and the risk for generation replacement in the agricultural exploitations. • Changes in consumers behaviour and diet, including emphasis for low-fat, plant-based, local and organic products. • Obligations from newly approved legislation, in particular in relation with biodiversity and reduction in pesticides. As recognized in the EU Bioeconomy Strategy, “the deployment of a sustainable European bioeconomy would lead to the creation of jobs, particularly in coastal and rural areas through the growing participation of primary producers in their local bioeconomies”. As such, sustainable bioenergy covers activities such as forest management, valorisation, research, maintenance, distribution, and operation, with higher implantation in integrated value chains with other bio-based industries. Altogether, bioenergy provides more jobs (703,000) than those supplied by all other renewable technologies, with an intrinsic focus on rural areas that offers a more inclusive distribution of income. On the other hand, the extension of teleworking partially due to social distancing policies to halt the spread of the COVID-19 but already existing beforehand, can bring new opportunities to rural areas: attracting qualified and digital workers, in turn providing a different lifestyle and lower housing prices than urban environments. Additionally, bioenergy is closely aligned to two priorities identified by the European Commission in the new proposal for a multiannual financial framework as enablers of the economic recovery post-COVID-19, the renovation wave and the rural development pillar of the CAP. To address these challenges and promote sectors with the potential to increase rural areas attractiveness and role in European society and economic system, Bioenergy Europe recommends the following aspects to be considered: • Recognising the preeminent role of rural areas in climate action, including negative emissions and the promotion of activities providing added value to mitigation and adaptation such as; afforestation, forest management, paludiculture and dedicated crops with the potential to increase the carbon sink in a sustainable and biodiverse-friendly manner. Additionally, perennial energy crops additionally improve environmental protection, providing all-year soil protection and protection from erosion, landscape management and improve phyto characteristics of the soil. • Addressing the specificity of rural areas, such as population dispersion and demographic structure and economic constraints, particularly logistic bottlenecks and the lower connection to utility networks: gas, internet and sewerage and include those factors in EU sectorial policy areas, especially the Next Generation EU, the European Green Deal and Europe’s Digital Future. • Incentivising climate resilience in rural areas through self-consumption and circularity, in particular in agroeconomy, promoting the use of agricultural residues as part of an enhance utilization of agricultural biomass and to avoid any food waste going to landfill in line with the Waste Directive. Valorisation of agri-residues provides an additional source of income and while avoiding open fire burning as management practice in line with the CAP’s good agricultural and environmental condition.
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Response to Strategy for smart sector integration

8 Jun 2020

Bioenergy Europe welcomes the effort to achieve further integration in the EU energy sector and bioenergy industry is already enabling the links between heating and cooling, electricity and transport sectors. However, Bioenergy Europe believes that the scope of the proposed roadmap should be broader to step up greenhouse gas (GHG) emissions reductions but also the economic recovery. In heating and cooling, given the lifespan of heating and cooling appliances (around 20 years) and the imminence of the renovation wave, all available technologies would be required to scale up to achieve carbon neutrality by 2050. The roadmap identifies “deep electrification of end use sectors” as one of the five broad areas of action. Besides the small share of electrification and renewables in the heating and cooling, electrification does not always equal today to GHG emissions reductions. Currently, electricity generation has a carbon footprint of near 300 g CO2 equivalent per KWh . Electrification investments in production and storage alone have been estimated in around €100 billion in societal investment every year by Eurelectric, without considering grid investments . As for bioenergy, The European Commission report on competitiveness of the heating and cooling industry and services signals biomass as the most competitive heating and cooling technology, and as such should be considered in the Strategy when addressing domestic heating. When the roadmap mentions the creation of new links in our energy system, it is worth to remind this is one of the main features of bioenergy industry. The utilisation and combination of both energy outcomes, electricity, and heat from the combustion, particularly through a combined heat and power (CHP) plant, increasing the efficiency of the process to levels around 90%. More than 70% of generated biopower comes from CHP plants and they provide the perfect example of integration between electricity and heating, especially for industrial and residential use, targeting two sectors mentioned in the consultation. In this same context, thermal storage allows to store energy in a cost-effective way, which can be directly used for heat needs such as space and water heating or 5th generation district heating and cooling or to use it for electricity production, depending on the needs. Bioenergy is also the natural source of renewable gases and fuels, providing long term energy storage and positive environmental externalities. Additionally, the sector thrives thanks to integrated and circular value chains with other industries, like agro-forestry, paludiculture or pulp and wood industries. In its review of 2050 scenarios achieving carbon neutrality, the JRC note the increased use of biomass for industrial purposes as a common trend among the scenarios. Bioenergy is closely aligned to two priorities identified by the European Commission in the new proposal for a multiannual financial framework as enablers of the economic recovery post-Covid19, the renovation wave by providing a renewable and cost-effective alternative for heating and cooling and rural development by providing an alternative source of income for farmers and agro-food industry. The EU smart sector integration strategy cannot forget a truly multisectoral source of energy with such a role for a decarbonised, interconnected and smart energy system and an enormous economic contribution and potential.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

Bioenergy Europe welcomes the Renovation Wave Initiative. A holistic approach towards renovations and integrated investments addressing building envelope and RES can increase the GHG emissions reductions from the building sector. As stated in the roadmap, the EU building stock is responsible for 36% of the EU GHG emissions and it is the largest single energy consumer in the EU with 40% of energy consumption, 21% of the total from residential. As 80% of EU households’ energy consumption is devoted to heating, there is an urgent need to decarbonise heating and cooling (H&C) sector. While around € 325b are required to meet 2030 climate and energy targets, current GHG target is under revision, which could increase societal costs. Therefore, cost-effectiveness and social and economic impact should be considered. Bioenergy is recognised as the only cost-competitive technology in the European Commission’s report on Competitiveness of the heating and cooling industry and services, having the potential to further reduce utilities bills addressing energy poverty. Bioenergy provides solutions for all opportunities mentioned in the roadmap in relation with the neighbourhood renovations: RES, advanced district H&C, waste management, sustainable mobility and social cohesion. Regarding the targeted buildings types for the Renovation Wave, Bioenergy Europe would like to stress the important opportunities offered in the application of modern biomass heating solutions in rural buildings, both public and private. The assistance of the Renovation Wave programme in the technology deployment offers a unique possibility for cross-compliance with numerous other policy objectives: • Windfall and cost-effective decarbonisation gains; 45 % of rural heat demand in Europe is coming from fossil fuels (heating oil and coal) . Substituting them with biomass would result in a substantial decrease of GHG emissions and wider deployment of RES across the heating sector. • Improving local air quality and alignment with CAP environmental objectives; replacing old appliances with new, modern bioheat ones has the potential to achieve reductions in air pollution up to 90%, according to CERIC. In addition, modern bioheat solutions can be set up based on the exploitation of local agricultural residues would mitigate air emissions from their disposal in open fires. This is also in line with the CAP GAEC requirements. • Supporting rural development; bioenergy provides more jobs (703,000) than all other RES, with an intrinsic focus on rural areas, offering a more inclusive distribution of income. • Supporting European technological leadership; EU manufacturers of biomass heating systems are at the forefront of the sector technological development worldwide. Promoting bioenergy is promoting European industry. There is a unique window of opportunity ahead of us: 80% of today’s buildings will still be in use in 2050 and 75% of this stock is energy inefficient according to the roadmap. The average lifespan of heating appliances is between 15 and 20 years, therefore the uptake of RES in buildings’ heating and cooling is not just an option if the EU is meant to reduce from 50 to 55% of GHG emissions by 2030 and to become carbon neutral by 2050. Renovation should aim for 100 % renewable-based and public money should be exclusively devoted to RES, including RES-hybrid. State aid for fossil fuels should be also ended. While most of the MS have submitted their national and energy plans, just five have presented their long-term renovation strategies under the revised EPBD. These strategies, and the comprehensive assessments under art 14 EED, should be the basis to support RES in building, especially in H&C.
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Response to Union renewable Financing mechanism

3 Jun 2020

Bioenergy Europe welcomes the Commission’s draft of an implementing regulation on the Union Renewable Energy Financing Mechanism. To facilitate the achievement of at least 32 % target of renewables share in gross final consumption of energy before 2030, additional financial measures dedicated to the development of renewables as well as the revamping of existing renewable assets are needed. Particularly, in the challenging time of economic downturn, the EU must show and prove its commitment to the green and low carbon transition. In this regard, we would like to underline that there are strong synergies between the proposed Renewable Energy Financing Mechanism and other EU initiatives, namely the Recovery Package, the Just Transition Fund and Modernisation Fund, which all will provide resources for investments in renewable energy sources. Therefore, we encourage and recommend a policy design that will ensure coherence among those different financing schemes. Certainty and stability of financing is a key factor helping to de-risk and reduce the cost of capital for renewable energy projects. Uneven capital costs across the EU are impeding faster RES roll out. Well-crafted financial support from the EU has potential to tip the market balance in favour of projects, which would not be implemented otherwise. This is particularly true and necessary given the recent evolution of CO2 prices, which does not suffice to drive a transition to a renewables-based energy system. If a sustainable and well-balanced generation mix is a true priority for every MS, competitive calls, although technology neutral, should eventually apply correction factors. Article 4 envisages different sources of financing. In Bioenergy Europe’s view it is necessary to allocate fresh financial resources from the EU budget to this initiative. The financial contribution of the EU which is limited to transfers from other Union programmes is likely to be insufficient. Additional funds on top of already enlisted sources of financing would increase the credibility of the instrument and encourage Member States to contribute and multiply its impact. Article 19 refers to the eligibility and selection criteria of projects, which will be established in the call for proposals for the Mechanism. Bioenergy Europe recommends that the selection criteria encompass wider economic impact of investment, particularly number of created jobs and contribution to the local economy. Such estimation would provide a guarantee that selected projects not only support decarbonisation but also an economic recovery and just transition, providing coherence with other EU financing instruments. We remark that defending and enhancing existing plants is a good strategy to take advantage of recent investments as well as to minimise environmental impacts on new sites. As revamped and repowered plants could represent a wide portion of the targeted generation capacity, the implementing mechanism should be open to repowering and revamping projects. Given the important environmental and industrial benefits, it is essential to ensure continuity of operation and the modernisation of the existing renewable assets (especially at the end of their incentive period) in order to reach Member States targets from RES in 2030. In this regard, we propose to place more value on the biomass sector. In fact, differently from other renewables, bioenergy is programmable and base load source. Bioenergy Europe reminds that biomass-based generation technologies, despite their added value in terms of system’s safety and positive social impacts, are running out of support schemes in numerous MS. At the end of the incentive period, many biomass plants are still efficient, but their viability is limited by high operational costs, largely due to the continuous need of input material. Given these circumstances, an early stop of some power lines could happen, with major risks of losing a valuable renewable energy supply at EU level.
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Response to Climate change mitigation and adaptation taxonomy

26 Apr 2020

Bioenergy Europe (BE) welcomes the objective of the taxonomy to help identifying the economic activities considered environmentally friendly and ultimately supporting the growth of low carbon sectors. In the present initiative, reference to Art. 14 of the Taxonomy Reg., including the requirement to assess the alignment of the technical screening criteria with existing EU legislation is sensible. BE supports a proportionate impact assessment to accompany the drafting of the delegated act and recommends that coherence is sought with the existing legislative framework. Metrics and screening criteria will play a key role for the definition of economic, social and environmental impacts of the taxonomy regulation. Unfit or impractical criteria will move investment away from those sustainable activities that cannot bear the administrative costs of compliance (small forestry holdings). Since the initiative will benefit from the work of the TEG, BE welcomes this opportunity to react to the recently published TEG report. The final report acknowledges the essential role of bioenergy to ensure the decarbonisation of EU economy, yet the metrics are still inconsistent with REDII and could hamper the sector’s competitiveness. BE welcomes the inclusion of bioenergy equipment suppliers in the list of Manufacture of Low Carbon Technologies. It is worth reiterating that bioenergy is today the largest renewable energy source in Europe providing 11% of EU energy supply. In addition, of the bioenergy industry’s value-chain is deeply rooted in the EU with 50.000 business units working to the further deployment of the sector. The existing legislative frameworks laid out in the REDII and that will be implemented starting July 2021 constitutes a solid basis to guarantee sustainability of the sector. Any inconsistency of metrics and thresholds selected in the TEG report with the existing legislation is concerning. The report introduces an all-encompassing incremental 80% GHG emission reduction threshold. The threshold is not in line with the one imposed by REDII, the conversion to gCO2e/KWh moves away from the conversion grid of REDII Fossil Fuel comparator, disregarding specificities of the electricity, cogeneration, heating and transport sectors. As for the biomass cogeneration sector, the technical annex refers to a power-to-heat ratio to draw an equivalence between the declining emissions intensity threshold set on the production of electricity and that applies to production of H&C. This equivalence is missing from the technical annex and it is hence unclear how this important threshold will be calculated. The screening criteria proposed for the forestry sector are not aligned with existing legislation nor reflect industry standards: biomass used today is often a residue of sawmill and other forest-based industries where traceability to a forest plot would be impossible. TEG’s proposal that for the production of biomass, only Annex IX part A feedstock are eligible is contradicting REDII where sustainable bioenergy has clear requirements. While for Existing forest Management, adaptation responses shall comply with the requirement set out in Art. 29(7)b of the REDII, for the mitigation responses 3 additive criteria are introduced. These are not consistent with REDII and no certifications to date can ensure compliance ( (2) Verified baseline GHG balance of relevant carbon pools at the beginning of the afforestation/reforestation activity). Forest holdings where biomass is sourced are often smaller than 10 ha. Biomass is a residual product with a low profit margin and, hence, the earnings for small forests and farms would not cover for the administrative costs of compliance (e.g. engaging consultants to certify GHG balance down to forest plot or field level). What is more concerning from a formal and substantial viewpoint is that the TA disqualifies RED II. BE recommends that the risk-based approach should be fully adopted as a mitigation response.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

Bioenergy Europe would welcome the revision of the Industrial Emissions Directive (ITD). The transition towards carbon neutral economy requires an appropriate legal framework providing a legal certainty for all participants of the market. In this regard we underline the importance of clarification of IED article 42 (1) which defines the scope of the application of the special provisions for waste incineration and waste co-incineration. The current wording of article 42 (1) is difficult to interpret and this causes significant issues for national authorities granting environmental licences based on it. Bioenergy Europe would support an improved version of article 42(1) to: • set end-of waste criteria for producer gas in line with emission limits. • benchmark against which to assess the possible adverse environmental or human health impacts of the 'non waste' when producer gas is combusted and treated would be the emissions resulting from the (co)-incineration of the product as if it were waste. Such clarification would increase the consistency of Member State implementation of IED requirements. Widespread utilization of co-gasification is in line with circular economy and climate targets as it can raise the efficiency of waste incineration. The European Commission published a non-paper drafted in cooperation with national experts to tackle the ambiguity of article 42. The solution proposed by the Commission in the mentioned non-paper “Gasification of waste under Directive 2010/75/EU on industrial emissions (IED)” is satisfactory. However, to guarantee long term investments, this non-paper, does not provide sufficient legal certainty and stability. Therefore, we urge the European Commission to clarify this article in a legally binding manner. Furthermore, Bioenergy Europe insists that legislative coherence is sought. Achieving a truly Circular economy and decarbonising EU industry are both important and mutually reinforcing goals. A revised IED should be consistent with these objectives. It should be underlined that Greenhouse gas emissions savings are already regulated under the EU Emissions Trading Scheme (ETS): IED should not include new GHG-emissions abatement measures but rely on the EU ETS framework to achieve this goal. As for the circular economy, the relevant promoting actions are mainly based on a value chain approach whilst the IED focuses on a single installation. Finally, broadening the scope of the IED to installations with a rated thermal input equal to less than 50 MW is unnecessary since those installations are already regulated under the Medium Combustion Plant Directive. There is no regulatory gap to be filled with broadening the scope to installations in current sectors just below the existing threshold. The necessity of adding sectors that fall outside the scope of the IED should be carefully assessed and consulted with the relevant stakeholders and industrial sectors and a thorough impact assessment should be carried out in advance. The IED’s purpose and scope is relevant and it should not be extended. During the process of its revision attention should be paid to avoid overlaps, or inconsistencies with other relevant EU legislation.
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Response to 2030 Climate Target Plan

14 Apr 2020

Bioenergy Europe welcomes the Roadmap on the 2030 Climate Target Plan and supports the upcoming impact assessment guiding informed policy design on (i) how to increase the ambition in a manner that best contributes to sustainable and inclusive growth, (ii) ensuring that the EU has access to a secure, affordable and sustainable energy system and (iii) that negative emission technologies (including nature-based and technology-based solutions) are promptly scaled up. Considering the insufficient progress towards Paris objectives, the EU needs to lead by example. In this context, climate targets for 2030 must be increased to prepare the EU for the transition towards carbon neutrality by 2050, achieving a more gradual annual GHG emissions reduction path and acceptable distribution of efforts. Bioenergy Europe is supportive of an at least -55% GHG emissions reduction by 2030. With energy currently accounting for more than 75% of total emissions in the EU, increasing the share of renewables in the energy mix is crucial. A 50% renewable energy target would deliver the right message to the market, for investments to flow towards renewable technologies. Energy efficiency will also play a key role in the achievement of the 2050 targets: the renewable energy target and the energy efficiency one need to be mutually reinforcing. With variable renewables being increasingly part of the EU electricity mix, the demand for flexibility services will also increase. Bioenergy is a reliable companion to variable renewables and market-ready to deliver the flexibility necessary to the security of the grid. For this reason, power generation based on solid biomass and sustainable bioliquids must be considered a crucial component of the mix beyond 2030. While increasing electrification is a reality, this is not the univocal solution to an effective energy transition. The EU Green deal's success depends also on the decarbonization of the heating and cooling sector, representing half of EU energy consumption. In this segment, the share of renewable energy sources has been growing at a slower pace than in the power sector. RES represents only 20% of energy used in this sector, with 16.9% provided by bioenergy alone. Strengthening the current article 23 of Renewable Energy Directive, including a binding renewable heat target would trigger much-needed investments in this area. Reaching half of the heating and cooling sector powered by renewables by 2030 would be possible and sustainable. To get to this objective, Bioenergy Europe believes that the renewable heat target produced by the Member States should be a binding one and increased to 3.1 pp annually. Alignment of the current Energy Taxation Directive with current climate goals should also be envisaged. Energy taxation should be based on energy content and on CO2 emissions, providing a common framework for CO2 pricing in the internal market. Such measures would help to decrease fossil fuel import dependency, promoting the development and consolidation of EU local supply chains of renewable sources. To minimize the social impact of increased tax rates for fossil fuels in the heating sector, potentially worsening energy poverty, it is essential to develop a policy framework supporting the modernization of heating stock in Europe. Similarly, biofuels will be instrumental in the much-needed decarbonisation of transports. Increased targets for 2030 will promote the use of renewable energy solutions which in the case of bioenergy are for the majority, locally produced. As stressed by IPCC and by the 2018 in-dept analysis supporting the Commission’s vision for a climate-neutral economy, achieving carbon neutrality will be possible only if the EU can increase its CO2 emissions absorption capacity over time. A clear path is needed to support negative emissions technologies development together with an increase of sustainable use of bio-based products and nature-based solutions.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

Bioenergy Europe would welcome the prompt revision of the Energy Taxation Directive (ETD). At the time of its adoption, the ETD represented a positive contribution to the EU’s legislative framework. As it has remained unchanged since 2003, it no longer reflects the evolution and progress in technologies, energy markets and the EU legislative framework in response to the climate emergency. The success of the European Green Deal requires now an urgent alignment of taxation of energy products and electricity with EU energy and climate policies. An adequate fiscal framework for energy products can substantially contribute to the EU’s 2030 energy targets and climate neutrality by 2050. The key paradox preventing such an alignment is the persistence of fossil fuel subsidies and tax exemptions. Bioenergy Europe calls for a removal of different forms of tax exemptions and reductions for fossil fuels which distort level playing field among fuels and technologies, hampering the functioning of the internal market. The low penetration of renewable energy (RES) in the heating and cooling sector is a case in point: RES represent only 20% of energy used in this sector, with 16.9% provided by bioenergy alone. Currently, taxation on fuel and energy products would be the only tool for installations below 20 MW of thermal input to be accountable for the CO2 emission they generate. In several Members States, indirect fossil fuels subsidies in heating sector persist in the form of tax rates reductions or full exemptions. Such a situation is detrimental to renewables-based solutions and ultimately undermines our efforts to achieve carbon neutrality by 2050. The key policy tool to be used in achieving the above-mentioned alignment is well-designed excise rates reflecting negative externalities from fossil fuels use. In the field of transport fuels, the current volume-based taxation has caused unintended effects on the market, as renewables solutions are often taxed more than fossil fuels. The EU transport sector is responsible alone for 22% of the EU’s greenhouse gas emissions and is regarded as a ‘hard to abate’ sector. The share of RES in the transport sector is equal to 8.03% mostly provided by biofuels. Therefore, if the EU wants to progress with the decarbonization of transport, the revisions of ETD is a matter of urgency. Furthermore, the current volume-based approach to the taxation of fuels is disadvantageous for high blend biofuels with a lower energy content than their fossil alternatives. New investments in advanced biofuels and research for the new solutions to be used in the aviation and maritime sector are also discouraged. Such measures would help to decrease oil import dependency, promoting the development and consolidation of EU local supply chains of renewable sources. It is of utmost importance to raise the levels of fossil fuels minimum taxes to a higher level which would make ETD coherent with the EU climate targets by putting in place taxation based on energy content instead of volume. The Revised Directive should allow member states to differentiate between the minimum tax levels for renewable, low-carbon fuels and fossil fuels. In this respect, Bioenergy Europe suggests that the revised ETD sets credible minimum excise rates, with a workable indexation mechanism. Energy taxation should be based on energy content and on CO2 emissions, providing a common framework for CO2 pricing in the internal market. CO2 Pricing is becoming increasingly important to safeguard competitiveness of RES in the EU, in face of the current extraordinary low fossil fuels prices. To minimize the social impact of increased tax rates on fossil fuels in the heating sector, it is essential to develop a policy framework supporting the modernization of heating stock in Europe switching from fossil to renewable options. Adequate support measures should be unlocked to help households and businesses to face capital costs of the required modernization.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

11 Mar 2020

Bioenergy Europe welcomes the plan for the establishment of Just Transition Mechanism (JTM) and the proposal of its core element, the Just Transition Fund (JTF). This is a much-needed instrument, helping to address existing and future socio-economic challenges the transition towards a carbon-neutral economy will pose. Bioenergy Europe supports ‘investments in the deployment of technology and infrastructures for affordable clean energy, in greenhouse gas emission reduction, energy efficiency and renewable energy’ as one of the eligible areas of JTF spending. Bioenergy is key to the achievement of the long-term carbon neutrality target and its increased use will provide for green jobs. It currently represents 58.6% of renewable energy consumption and 11% of energy consumption in the EU. Its versatility is allowing to decarbonise several EU sectors: buildings, power, transport and industry. It is proven by the case of Lithuania, which was able to phase down imported fossil fuels with domestically sourced sustainable biomass, improving both GHG reductions, security of supply while delivering substantial cost savings. In the EU, there is an large potential for fossil fuels substitution in both the electricity and heating and cooling sectors with sustainable biomass. Such actions would facilitate decarbonisation of the power sector and protect local jobs through reskilling for the green economy. Affordability of the bioenergy would guarantee also that energy poverty problem is addressed properly. Such investments should be eligible for support from JTF sources. Bioenergy’s value chain is predominantly local. Bioenergy equipment manufacturing is solidly based in EU while net import of biomass equals only to 4% of the EU’s biomass primary energy production. Sustainable biomass sourcing provides stable, long term benefits for local economies. Currently the bioenergy sector employs 703 200 workers directly and indirectly, making it the largest renewable in terms of employment. According to review of scientific literature (Faij, 2017) the sector can sustainably triple its contribution to the energy mix and cover half of the EU energy demand by 2050. Its dynamic growth would provide synergies with local economies, by creation of highly skilled jobs and additional streams of revenue for farmers, foresters and communities. The Regulation establishing Just Transition Fund foresees also development of Territorial Transition Plans which elaborate on the measures to be implemented in particular regions. For the sake of coherence and business certainty, Bioenergy Europe underlines the importance of their consistency with National Energy and Climate Plans. Bioenergy Europe appreciates that ‘investment related to the production, processing, distribution, storage or combustion of fossil fuels’ are not entitled to financial support from JTF. In this regard, we underline that such an approach should be coherent within the entire JTM. Investments eligible for support within Invest EU scheme may include gas infrastructure. This could lead to a lock-in effect: lifetime of large gas fire plants is at least 20 years and currently only 0.4% of consumed gas is renewable. As the President of the European Commission Ursula von der Leyen underlined “leave no-one behind” should be the guiding principle of the EU economic transition towards a climate friendly model. The success of the EU Green Deal depends on its social acceptance. Therefore, it is necessary to improve the economic resilience of the most coal-dependent regions and facilitate the professional mobility of their workforce. Bioenergy deployment would have a positive impact in local jobs and employment.
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Response to Climate Law

5 Feb 2020

Bioenergy Europe welcomes the European Commission’s efforts to put sustainability at the heart of its policies. The European Green Deal, presented on 11 December 2019, is a well-balanced growth plan which will steer the transition toward a carbon-neutral economy. Bioenergy Europe supports the intention to enshrine the principle of carbon-neutrality in binding legislation. Bioenergy is key to the achievement of this target: it currently represents 58.6% of renewable energy consumption and 11% of energy consumption in the EU. The biomass used is predominantly local (around 4% import) and mainly sourced from sustainably managed forests. Its versatility is allowing to decarbonise several EU sectors: buildings, power, transport, and industry. Energy is the source of 78% GHG emissions in Europe, with transport and heating sectors together being responsible for 45% of EU28 GHG emissions. In 2017 thanks to bioenergy utilisation 303MtCO2eq were saved. This equals to 7% of EU28 GHG emissions, around the annual emissions of Spain. If the EU wants to stand a chance to hit its climate and energy targets, it needs to invest in technology innovation while fully deploying the potential of existing technologies to drive the transition. The transition of the EU economy towards a sustainable and climate-friendly model requires a stable and long-term legislative framework for economic operators and stakeholders to contribute and confidently invest in the future’s technologies. For this reason, establishing a binding EU-wide 2050 carbon neutrality objective is a rational initial step. The achievement of such an objective will require a prompt adjustment of the mid-term climate and energy objectives measures. Bioenergy Europe believes that the EU should: - Correct the GHG emissions saving trajectory by increasing its 2030 GHG emission savings target to at least 55% - Acknowledge the key role of renewables in curbing emissions by increasing the 2030 renewable target, including renewable heating and cooling uptake: the EU energy mix should be based on renewables rather than on fossil fuels. The GHG emission savings target should be supported by sectoral objectives and milestones with climate and energy-related policy measures updated to achieve convergence. For example, special attention should be dedicated to the heating and cooling sector that, representing half of the current energy consumption is still dauntingly dominated by fossil fuels (80%). Bioenergy is flexible and adapts to different scales and needs: from domestic size to district heating; for residential, commercial and industrial heating. Renewable technologies have a comparatively low rate of penetration in the heating sector but among these, biomass is the undisputed leader with an 87% share. At the EU scale, biomass accounted for 20% of the overall residential heating consumption in 2017. To achieve a higher GHG emission savings target it will be therefore necessary to plan measures resulting in a prompt decarbonisation of the heating sector and modernization of the old heating stock with energy performant and renewable-based equipment to avoid lock-in. As underlined by the In-depth analysis in support of the EC strategic vision 2050, that will be used in lieu of an ad-hoc impact assessment for the Climate law, scaling up proven negative emissions technologies will be a necessary step to achieve carbon neutrality in the EU. Bioenergy coupled with carbon capture and storage or with biochar production are the most mature market solutions to date together with afforestation. In Europe, three BECCS pilot projects are currently being developed while several biochar facilities are already functioning. Bioenergy Europe believes that policy planning supporting the deployment of such solutions and establishing clear accounting rules and incentives for the negative emissions will be key if the EU is to count on their scale-up to become carbon neutral by 2050.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

27 Nov 2019 · The role of bioenergy in the clean energy transition

Response to European Partnership for a Circular bio-based Europe

26 Aug 2019

Bioenergy Europe welcomes the opportunity to provide feedback to the European Commission initiative to establish a European Partnership for a circular bio-based Europe under Horizon Europe. Bioenergy Europe welcomes the acknowledgement of the bio-based sector as a cornerstone to achieve the EU’s goal of building a climate-neutral future while creating greener and more inclusive growth and jobs. It is of utmost importance to include the bioenergy sector as one of the enabling actors of a comprehensive and effective circular bio-based Europe. Bioenergy is currently the EU’s largest renewable energy source (63,8% in 2016) and it will be a key component of the energy mix in 2030 enabling the transition to a carbon neutral economy by 2050. Bioenergy brings benefits in terms of energy security, competitiveness, growth and job creation. In this regard, the bioenergy sector created 659.000 indirect jobs in the EU in 2016 (EurObserver, 2018) and had a turnover of € 56.1 billion, substantially contributing to EU economic growth. Deployment of bioenergy and its synergies with other bio-based sectors will contribute to meet the EU renewable energy targets and to reduce dependency on non-renewable materials. Bioenergy Europe believes in the inherent circularity of the bioeconomy as this regenerates CO2 and uses renewable raw materials to make greener everyday products and energy. Bio-based products and materials have the benefit of achieving a balanced carbon cycle in comparison to fossil alternatives. In addition, bioenergy is the link to truly achieve a circular economy based on a better use of secondary materials, an efficient management of natural resources as well as a drastic reduction of waste and GHG emissions. Bioenergy closes the loop by offering bio-based industries with the opportunity of turning their waste into a valuable and green source of energy; by adding value to agricultural and forestry residues, and ultimately enhancing soil fertility through alternative fertilizers such as wood ash and digestate. Therefore, Bioenergy Europe supports the idea to coordinate research funding for circular and bio-based economy. The large untapped potential of the bioenergy sector and its synergies with other bio-based industries will not be achieved merely through project-based grants. For this reason, option 0 appears to be insufficient. Option 2 seems more solid as building on the experience of the Bio-based Industries Joint Undertaking, which could lead to positive environmental impact and long-standing synergies among involved sectors. To foster the development of an EU circular and biobased economy, the future initiative should be inclusive. Bioenergy solutions should be promoted along with other possible applications (chemicals, food and feed, etc).
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Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

14 Dec 2018 · Bio-economy strategy

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

3 Dec 2018 · views of the European bioenergy sector

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

5 Nov 2018 · Long Term Strategy and exchange of views on the EU bioenergy sector

Meeting with Dominique Ristori (Director-General Energy)

19 Oct 2018 · les atouts de la bioénergie en termes de développement économique, de création d'emplois mais aussi de sécurité énergétique et de réduction des émissions

Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

AEBIOM welcomes the initiative of the Commission to update the Bioeconomy Strategy. Biomass has great potential – both in terms of energy and material use – to decarbonise the European economy. The Bioeconomy Strategy will continue to play an important role in facing this challenge and should create further incentives for biomass in the coming years. Meeting European and international climate goals In line with the Paris Agreement to limit global warming at a maximum of 2°C, the European Union is in the phase of adopting higher targets for renewables in the European energy mix. Bioenergy in its different forms plays a crucial role, accounting for about 60% of renewable energy (gross final consumption) in Europe. According to a report by the International Renewable Energy Agency (IRENA), bioenergy will continue to account for more than half of renewable energies in the EU beyond 2030, especially in the heating sector and energy intensive industries. Meeting the renewable energy targets will thus strongly rely on bioenergy. The Bioeconomy Strategy will need to focus on both material and energetic uses to realise its full potential. This will require a wide involvement of stakeholders and Commission services to create coherent policy objectives. New potential for biomass With the uptake of the bioeconomy, the debate is increasingly focused on competitive uses of biomass. In this context, material and energetic uses of biomass should not be seen as mutually exclusive. Bioenergy strongly relies on biomass feedstocks from residues, but these could remain underutilised in over or poorly regulated scenarios. While market prices guarantee that high quality timber is used for products whereas low quality wood, such as branches and tops, are used for energy, one of the greatest challenges in Europe remains biomass mobilisation, rather than availability. Active and sustainable forest management can increase forest growth and resilience, as well as biomass availability. As outlined in the EU Forest Strategy, forest-biomass and agri-biomass have positive socio-economic impacts, especially in rural areas. Bioenergy is the largest renewable energy source in terms of job creation and employs around 500,000 people in the EU and should thus be seen as a driver of rural development. The Bioeconomy Strategy should take such potential into account and foster research and innovation. In the recent JRC biomass study , it was acknowledged that there are various methodological and data knowledge gaps for a comprehensive assessment of overall biomass potential. To ensure evidence-based policy making, the updated Bioeconomy Strategy should be based on sound, forward-looking scenarios of biomass supply and demand. Support innovation and market uptake Bioenergy can foster resource efficiency by using residues and waste as biomass input. There are promising synergies already taking place. Energy-intensive industries such as the pulp and paper industry use their residues to meet more than half of their energy demand via bioenergy. Biorefineries create a resource efficient production of both bio-based products and biofuels. However, small-scale solutions such as the combined use of local wood for heat in enterprises and households should not be neglected in the future. Moreover, environmental benefits arise through the substitution of fossil fuels. Agricultural biomass and dedicated non-food energy crops can provide ecosystem services such as fighting soil erosion and merit further incentives to be taken up by the market. The Bioeconomy Strategy should play a key role to foster innovation, increase market uptake and raise the awareness of decision-makers on the potential of various sources of biomass.
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Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

26 Jul 2017 · Topics related to the bioenergy sector

Meeting with Christiane Canenbley (Cabinet of Commissioner Phil Hogan)

26 Jul 2017 · Position of AEBIOM on bioenergy sustainability

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

4 Oct 2016 · Biomass

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

12 Sept 2016 · EU bioenergy sustainability policy

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

8 Mar 2016 · Biomass sustainability

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

24 Mar 2015 · Energy Union follow-up: cooling and heating