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Enviva

Enviva are the world’s largest producer of sustainable wood pellets, a renewable alternative to fossil fuels.

Lobbying Activity

Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius) and Drax Group plc and

6 Feb 2024 · wood pellet and EUDR

Meeting with Morten Petersen (Member of the European Parliament)

31 Jan 2022 · REDIII

Meeting with Asger Christensen (Member of the European Parliament)

13 Jan 2022 · Enviva

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and Drax Group plc and

18 May 2021 · Forest biomass and Fit for 55

Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson) and Drax Group plc and

18 May 2021 · To discuss the options that the Commission are currently considering for the review of biomass sustainability within the proposal for REDIII. To discuss the role of sustainable bioenergy in the EU’s energy and climate plans.

Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

We welcome the issuance of the REDII operational guidance. The REDII establishes strict, harmonized EU-wide criteria for bioenergy sustainability, and the implementation of these rules will provide important policy certainty for economic operators and industry investors. In order for supply chains, regulatory frameworks, and certification systems to continue uninterrupted, the European Commission should work together with Member States to prevent any regulatory gaps in the market and allow for seamless implementation and transposition. We have made some recommendations in the attached file that will bring the guidance more in line with a risk-based approach and ensure the guidance is appropriate across all regions and supply areas. We do not support further changes or renegotiation of the bioenergy sustainability criteria in REDII. The criteria were developed via 2 years of international stakeholder input and legislative debate. The science on bioenergy and it’s important role in climate change mitigation has not changed. As indicated by the JRC, swift implementation of the REDII will address additional sustainability concerns, and further, will provide the necessary policy certainty that is needed for bioenergy to continue to support the achievement of EU climate goals.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis), Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and

27 Apr 2021 · Biomass sustainability

Response to Climate change mitigation and adaptation taxonomy

14 Dec 2020

Enviva is a leading global energy company specializing in sustainable wood bioenergy. Our mission is to fight climate change by displacing coal and growing more trees. We do this by producing sustainable, renewable wood pellets and delivering them to customers around the world. Biomass sustainability is guaranteed via strict, harmonised, European Union-wide sustainability criteria included in Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (RED II). Together with risk-based forestry certification schemes this ensures the sustainability of biomass. We welcome that the Delegated Act is broadly based on existing EU sustainability legislation that has been fully scrutinized through the Ordinary Legislative Procedure. However, there remain significant issues that threaten to undermine investor confidence in biomass, impeding Europe’s path to climate-neutrality. Firstly, bioenergy for electricity, heat and CHP has been classified as ‘transitional’. This is in direct contradiction to Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (Taxonomy Regulation) which in Art. 10.1 clearly states that “generating, transmitting, storing, distributing or using renewable energy in line with Directive (EU) 2018/2001…” should be considered ‘substantial contribution’. A transitional activity is defined as one for which there is no “feasible low-carbon alternative” – bioenergy is inherently a low-carbon alternative. Biomass is included in RED II as it is part of the biogenic carbon cycle, whereby carbon absorbed and stored in wood over its lifetime is released when burned for energy, and the carbon is reabsorbed and stored by growing forests. This is acknowledged by the IPCC and forest and climate experts around the world – there is no scientific bases on which to change that assessment. Secondly, Annex I, Section 7.6 excludes bioenergy installations. This section is later referred to for maintenance on other renewable technologies. Maintenance and repair must be considered sustainable for bioenergy installations, especially as this activity will often include upgrades (e.g. filters) that improve the sustainability of the plant. Lastly, in order to ensure the EU can rely on a steady supply of sustainable biomass, which is essential to meeting its climate goals, the Taxonomy must be aligned with the criteria laid out in the RED II. Additional or separate criteria creates confusion in the marketplace impacting investor confidence and supply chain efficiency. Restrictions on ‘whole trees stems’ (Annex II, section 1.4) should be removed. The wood fiber that flows to the woody biomass industry is determined by its (low) value, not by its size or appearance. ‘Whole tree stem’ has no real meaning in forestry and could cover widely different trees, including diseased or crooked trees, pulpwood, large treetops, or thinnings (which support forest growth). Arbitrarily excluding such low-value feedstocks has no practical implications on forestry practices and does not enhance sustainability. The requirements for calculation of a GHG balance against a ‘business as usual’ comparison is unrealistic and impractical. There is no agreed method for determining the counterfactuals of activity in the forest. Forest markets are impacted by many external factors such as yearly rainfall, housing market, extreme weather, landowner preferences, commercial developments etc. GHG calculations that rely on a future anticipated outcome have too many variables and biases to be effective. A more realistic and reliable method is to use a historic reference point to make reasonable assumptions about forest inventory and forest carbon stock trends in the future. This method, alongside national inventories and data, is used to comply with RED II. The Taxonomy should remain consistent with this approach. Specific recommendations for amendments are provided in the attached document.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Enviva is a leading global energy company specializing in sustainable wood bioenergy. Our mission is to fight climate change by displacing coal and growing more trees. We do this by producing sustainable, renewable wood pellets and delivering them to customers around the world. We welcome the Commission’s intention to review state aid guidelines to ensure they are fit for the delivery of the Green Deal. We recognize the important role that state aid will play in supporting the EU’s transition to climate-neutrality. Sustainable biomass currently plays a critical role in decarbonisation and will continue to be necessary for the EU to meet its climate goals in 2030 and beyond. A JRC report from earlier this year (“Towards net-zero emissions in the EU energy system by 2050”) on the EU energy mix indicated that an increase in biomass usage from current levels will be needed to achieve net-zero by 2050. Further, in the recently published 2030 Climate Target Plans impact assessment, bioenergy remains the largest renewable across multiple scenarios, with further growth projected between now and 2050. Sustainable biomass is part of the biogenic carbon cycle, whereby the carbon absorbed and stored in wood over its lifetime is released when burned for energy, and that same carbon is reabsorbed and stored by growing forests. As a result, on a life-cycle basis using biomass in place of coal to produce electricity reduces carbon emissions by more than 85%, and just over 70% compared to gas. It’s dispatchability supports the integration of wind and solar, ensuring renewable power kicks in during intermittent periods. It is a readily available and low-cost alternative to fossil fuels in Combined Heat and Power. It can displace coal in producing high-temperature heat for industrial users and provides the most realistic pathway to negative emissions. As such, it is vitally important that any state aid that involves the use of forest biomass has the assurance that the biomass is sustainably sourced in a way that helps maintain forest health, grows the carbon sink and supports biodiversity as well as provide secure, reliable renewable energy. These positive environmental benefits are all ensured through the recently passed Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (RED II). This Directive has had extensive, international stakeholder input and a full impact assessment, and was developed in collaboration with, and fully scrutinized by, the European Parliament and the Council of the European Union through the Ordinary Legislative Procedure. Additionally, over the last 2 years, there has been ongoing development of detailed implementation guidelines by the Commission, which has included further stakeholder consultation and 12 months of technical analysis. For this reason, any state aid guidelines should be based on the sustainability standards set out in RED II. It would be inappropriate for the EU Taxonomy to be used not least as its robustness has been questioned by a variety of stakeholders. Indeed, we believe the EU Taxonomy should also be based upon RED II and have argued as such through other consultations and avenues.
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Response to EU Forest Strategy

4 Dec 2020

Enviva is a leading global energy company specializing in sustainable wood bioenergy. Our mission is to fight climate change by displacing coal and growing more trees. We do this by producing sustainable, renewable wood pellets and delivering them to customers around the world. We welcome and support the Commission’s ambition to bring forward measures to avoid or correct unsustainable practices, increase forest protection and restoration and ensure forests help to achieve the EU’s climate, biodiversity and socio-economic goals. Forests are multifunctional and, in addition to their role as habitats and carbon sinks, they can provide products that are a substitute for fossil-based materials. The Commission’s own Clean Planet for All analysis notes that material use of harvested wood products leads to lower greenhouse gas emissions over the whole life-cycle compared to functionally equivalent alternatives, saving between 1.5 to 3.5 tonne of CO2 per ton of wood product used. We ask that as the Commission updates the EU Forest Strategy, it uses terms that are recognised and understood by forest industries and uses Forest Europe concepts of Sustainable Forest Management to avoid confusion and so ensures the best possible implementation of any new measures. Biomass for energy can help deliver the goals of the EU Forest Strategy through the following: i) Biomass can help prevent disease and forest fires. Working, sustainably managed forests have many benefits, including creating a variety of landscapes and tree ages, which each providing habitats and benefits for a variety of wildlife. Additionally, markets for wood products provide incentives for private (often family) forest owners to replant and sustainably manage their lands, leading to increased forested area, wildlife habitats and habitat connectivity. Thinning (the removal of weaker, diseased or crooked trees), improves the growth of remaining trees, reduces the risk of wildfire and disease, and creates open canopies supporting wildlife habitat. These open canopies enable sunlight to reach the forest floor, allowing shrubs and brush to grow, which is necessary for wildlife nesting, protective cover and food. An available market, such as paper or biomass, for those removed trees is critical to ensure essential forest maintenance is economically feasible. ii) Demand for sustainable forest products creates more sustainable forests It is vital that any forest product is sustainably sourced. This is achieved in the energy sector through the strict, harmonised, Union-wide criteria for all biofuels, bioliquids and biomass fuels, within the recast of the Renewable Energy Directive (RED II). These criteria, together with risk-based forestry certification schemes, guarantee the sustainability of biomass, ensuring: the legality of harvesting operations, the regeneration of the harvested area, nature protection, maintenance of soil quality and biodiversity and that the long-term production capacity of the forest is maintained or improved. One of the biggest threats to forests and biodiversity is lost habitats through land conversion. Although underpinned by RED II this has been guaranteed in our main sourcing region, the US Southeast, by a thriving market for wood products which has supported the expansion of forest inventory by 21% in the last decade. iii) Biomass can replace fossil fuels. Biomass has been crucial for taking coal off the grid in Europe: it facilitates a one-for-one replacement for coal, is dispatchable and thereby supporting intermittent renewables such as wind and solar, and allows for the preservation and creation of jobs at former coal plants. Benefits that are available fast and affordably. Now, together with Carbon Capture and Storage forest biomass can help create negative emissions, as being demonstrated by Drax in the UK.
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Response to New EU Soil Strategy - healthy soil for a healthy life

3 Dec 2020

Enviva is a leading global energy company specializing in sustainable wood bioenergy. Our mission is to fight climate change by displacing coal and growing more trees. We do this by producing sustainable, renewable wood pellets and delivering them to customers around the world. We recognise that healthy soils are a key enabler to achieve the objectives of the European Green Deal. The biomass industry, together with the broader forest product industries, play an important role in protecting and enhancing soil health, fertility and reducing erosion. Sustainable forest management (SFM) promotes healthy forests Sustainable forest management, an established forestry practice which includes soil management, prevents the spread of wildfires and diseases, promoting healthy forests, preventing erosion and increasing the forest floor and its capacity to absorb carbon. A key tool for SFM is thinning, which involves the removal of weaker, diseased or crooked trees, in order to improve the growth of the remaining trees, reduce the risk of wildfire and disease, and create open canopies. Opening the forest canopy means that the forest floor – i.e. the soil – receives more sunlight, water and nutrients, thereby enhancing the health and quality of the soil. Thinnings are economically feasible because there is an available market, such as paper or biomass, for the low-quality wood that comes from the removed trees. Markets for forest products create more forests and prevent soil loss At the same time, markets for forest products are incentivising forest owners to keep their forests as forests and to increase forest area. More forests prevent soil erosion, and more forest floor means more carbon absorption. Forest owners' confidence in the market for their wood means they invest in their forests’ health and preventing disease and infestation, do regular maintenance to reduce the risk of natural disturbance, like wildfire, and replant trees for the next generation. It is important to note that demand for wood products prevents forest conversion to other land uses, like development, and preserves economic and environmental benefits. It is this robust market for wood products that has supported the expansion of forest inventory by 21% in the US Southeast in the last decade. Biomass from the US Southeast is a trusted partner In addition to federal level legislation which ensures that soil health and fertility are being protected and enhanced, state-level forest best management practices (BMPs) also play an important role as they include requirements for forest harvests and management. Violation of BMPs come with their own fines and jail time penalties. Further still, the EU has its own rules that ensure soil quality in relation to biomass. The sustainability criteria for biomass included in the 2018 Recast of the Renewable Energy Directive ensures that biomass can only be used if harvesting is carried out in a manner that accounts for the maintenance of soil quality.
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

Enviva is a leading global energy company specializing in sustainable wood bioenergy. Our mission is to fight climate change by displacing coal and growing more trees. We do this by producing sustainable, renewable wood pellets and delivering them to customers around the world. We welcome the urgent attention that the Commission is giving to restoring degraded ecosystems, in particular those with the most potential to capture and store carbon and to prevent and reduce the impact of natural and man-made disasters. We welcome the focus on ensuring no deterioration of ecosystems following their restoration. For this to happen, it is vital to take a holistic view of forests taking account of environmental and economic perspectives. The greatest threat to forest growth is conversion, so bringing biodiversity and economic viability together will ensure that forests can both grow and stay healthy. As such we encourage the Commission to use as reference the 2018 Recast Renewable Energy Directive that introduced strict, harmonised sustainability criteria which, together with risk-based forestry certification schemes, ensures biodiversity and forest health is maintained. We are proud to be playing our part in supporting healthy forests, particularly in our main sourcing regions in the US Southeast. For example: The use of biomass encourages forests to stay as forests: Markets for wood products provide incentives for private (often family) forest owners to replant and sustainably manage their lands, leading to increased forested area and wildlife habitats, as well as ensuring habitat connectivity, which is critical for wildlife. The use of biomass helps forests to stay healthy: Working, sustainably managed forests have many benefits, including creating a variety of landscapes and tree ages, which each provide habitats and benefits for a variety of wildlife. Thinning (the removal of weaker, diseased or crooked trees), an established sustainable forest management best practice, improves the growth of remaining trees, reduces risk of wildfire and disease, and creates open canopies supporting wildlife habitat. These open canopies allow for sunlight to reach the forest floor, allowing shrubs and brush to grow, which is necessary for wildlife species for nesting, protective cover and food. Therefore, restricting the use of whole trees such as thinning for bioenergy, as proposed in the EU Biodiversity Strategy could have a negative effect on forest health. The use of biomass encourages the use of natural forest regeneration practices: Diversity of trees is encouraged as forest owners know that all trees will have a value – whatever species or shape. A harvest is almost never undertaken for bioenergy owing to its very low market value – restricting the use of whole trees for bioenergy, could encourage conversion of forests to monocultures. Furthermore, ensuring that weaker trees are removed ensures that stronger trees are more likely to be the seed trees for the next forest growth resulting in a stronger, healthier forest. Biomass from the US is a trusted partner: There are many biodiversity and wildlife protections and monitoring systems already in place in the US that can be replicated and relied upon to address EU climate goals. Such as: • Sustainable Forestry Certifications – US pellet manufacturers use a variety of internationally-recognized risk-based forestry certification schemes to demonstrate and verify sustainability. • Forest Best Management Practices – The US South employs forest best management practices (BMPs), which help private forest owners comply with federal and state environmental laws and regulations, such as the US Endangered Species Act (ESA). • USDA Forest Inventory and Analysis Data (FIA) – US forest ecosystems are monitored closely through the FIA program, which routinely reports on forest health and growth, carbon stocks, and biological diversity.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

Enviva is a leading global energy company specializing in sustainable wood bioenergy. Our mission is to provide an alternative to coal and grow more trees. We do this by producing sustainable, renewable wood pellets and delivering them to customers around the world. Sustainable wood energy can support the Commission as it seeks to ensure i) forests sequester more carbon, ii) biomass supports forest growth and iii) biomass supports biodiversity and prevents forest fires and pest outbreaks. i) Ensuring forests sequester more carbon A recent study published in the scientific journal Nature, produced by an international team who from 2005 to 2017 conducted a systemic assessment of 123 areas where wood pellet mills operated, found a net expansion in the amount of carbon stored in Southeastern US forests. Biomass plays a key role in this expansion by providing a market for the removal of trees that support forest health (thinnings) which ensures a forest sequesters more carbon during sequential forestry cycles. Accurate reporting on LUC is guaranteed by the US Environmental Protection Agency, who uses UN reporting methods to calculate emissions and removals and annually reports inventories to the UNFCCC. ii) Ensuring biomass supports forest growth The US Southeast has a forested area larger than the total land area of Germany, Spain and Italy combined. According to the USDA Forest Service, private forest owners in this region are growing 40% more wood than they remove every year. Demand for a range of wood products provides financial incentives for private landowners to preserve their forests as forests, continue replanting, and sustainably manage their lands. As such the US Southeast has seen continuous growth in forested area, forest inventory, habitats and forest carbon stocks since the 1950s, despite record population growth and urban development during this same period. iii) Ensuring biomass supports biodiversity and helps prevent forest fires and pest outbreaks Working, sustainably managed forests have many benefits, including creating a variety of landscapes and tree ages, which each provide habitats and benefits for a variety of wildlife. Additionally, markets for wood products provide incentives for private forest owners to replant and sustainably manage their lands, leading to increased wildlife habitats, as well as ensuring habitat connectivity across the US Southeast region, which is critical to wildlife. Thinnings, as well as improving growth of the remaining trees, reduce risk of wildfire and disease, and create open canopies. These open canopies allow for sunlight to reach the forest floor, meaning shrubs and brush can grow, providing nesting, protective cover and food for certain species. 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. These criteria, together with risk-based forestry certification schemes, underpin the sustainability of the biomass we produce. With REDII only coming into force in 2018, it would be counter-productive to introduce further measures at this time. Achieving the EU’s ambitious 2030 and 2050 climate targets requires multiple solutions. Sustainable biomass has proven to be a fast and reliable way to decarbonize the economy due to its ability to replace coal 1:1 and provide dispatchable power, supporting the integration of wind and solar. It is also a viable and low-cost alternative to coal in Combined Heat and Power and for producing high-temperature heat for industrial uses. Furthermore, bioenergy with CCS (BECCS) is now a proven technology providing a viable pathway to much needed negative emissions.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Enviva is a leading global energy company specializing in sustainable wood bioenergy. Our mission is to provide an alternative to coal and grow more trees. We do this by producing sustainable, renewable wood pellets and delivering them to customers around the world. Sustainable biomass is central to reducing European carbon emissions and meeting ambitious 2030 and 2050 climate goals. It’s dispatchability supports the integration of wind and solar, ensuring renewable power kicks in during intermittent periods. It is a readily available and low-cost alternative to fossil fuels in Combined Heat and Power. It can replace coal in producing high-temperature heat for industrial users and provides the most realistic pathway to negative emissions. This vital role is underpinned by the zero-rating rightly afforded to biomass under the EU-ETS. There have been misguided challenges to this. As such the Commission should bear in mind: Biomass is part of the biogenic carbon cycle, which recycles carbon in the atmosphere: the biogenic carbon cycle is a process whereby the carbon absorbed and stored in wood over its lifetime is released when burned for energy, and that same carbon is reabsorbed and stored by growing forests (ensured by RED II). This process is markedly different to fossil fuels, which release additional carbon into the atmosphere that otherwise would have been stored underground. The biogenic carbon cycle is acknowledged by the IPCC, understood by forest and climate experts around the world, and is the crux of biomass’ zero-rating. Biomass supports forest health and growth, leading to increased carbon storage: Enviva sources from the US Southeast, a forested area larger than the total land area of Germany, Spain and Italy combined. Private forest owners in this region are growing 40% more wood than they remove every year. This is because of the financial incentive that landowners receive from markets for forest products, which encourages replanting and sustainable management of their forests. At the same time, only a small fraction of forest resources in the US Southeast are harvested every year for forest products (less than 4%). In our sourcing areas carbon stocks and forest growth are on an upward trajectory. As long as this net growth continues there is no 'carbon debt' or 'payback period'. Biomass significantly reduces carbon emissions in comparison to fossil fuels: Sustainable wood energy does release emissions along the supply chain, in manufacturing, processing, and transport. Even accounting for these, using wood energy instead of coal reduces carbon emissions by almost 90%. The RED II includes strict Greenhouse Gas standards that biomass must meet under EU law. The Intergovernmental Panel on Climate Change (IPCC) has long been a supporter of bioenergy as a critical climate change mitigation tool: In their recent special report on land use in August 2019, the IPCC indicated that all scenarios that keep the planet's warming below 1.5C include combinations of biomass for energy production, afforestation and reforestation, and carbon capture. Sustainably produced wood pellets support all three of these areas Negative Emissions through Bioenergy with CCS (BECCS): Of the IPCC’s 116 scenarios for keeping global warming to 1.5C, 101 rely on negative emissions technologies. BECCS is one of the most scalable and promising technologies. The world’s largest bioenergy producer, Drax Power, are already capturing one tonne of carbon per day and aim to capture 16 million tonnes per year of negative emissions. The EU-ETS has shown that creating carbon markets has been an effective tool for reducing emissions. A market mechanism can also play an important role in supporting the innovation needed to scale up and deploy negative emissions. As such the impact assessment should consider this option within the framework of the EU-ETS.
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Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

12 Sept 2016 · Biomass/Bioneregy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and Edelman Public Relations Worldwide

12 Sept 2016 · Biomass