Estonian Forest and Wood Industries Association

EFWA

Develop competitive forest- and wood industries in Estonia through sustainable forestry, innovative production and innovative use of wood.

Lobbying Activity

Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

The Estonian Forest and Wood Industries Association find the draft guidance excessive and stretching beyond the mandate given by REDII. Estonian Forest and Wood Industries Association is expecting guidance that provides examples for verification and workable tools. By and large, the draft guidance is missing these. At the same time the guidance is trying to broaden the scope of the co-legislated REDII directive. Coherence in the interpretation of the measures and timeliness in transposition and implementation are paramount in preventing barriers to the internal market. We find it very unfortunate that the Commission is significantly delayed with this implementation act. That is particularly problematic as the REDII directive set the deadline for guidance by the end of January 2021. In parallel the commission has insisted that the Member States must implement REDII in time. This legal non-synchronization may create unnecessary biomass market turbulence in the near future. In Estonia and in ohter Baltic states, biomass diverted to bioenergy represents a minority of wood volumes and the wood-based industry. It is in reliant on being is harmony with the non-energy wood sectors. Bioenergy will not have any notable influence of forest management practices. The guidance should aim to mirror the current sustainable forest management practices and not aim to change them for the lowest quality biomass. Going beyond normal forest management will leave lowest quality wood to no use or landfills. The guidance should not aim to specify and give preference to sustainable forest management methods and frameworks on short term and medium-term basis. Long-term management plans and harvest methods should be preferred to maintain or enhance long term sustainability benefits. Including clear-fells, seeding and natural regeneration. The sustainability criteria within the REDII and the currently used verification schemes ensure that biomass is sourced sustainably and used effectively. The increased ambition within the Green Deal will impact efficiency and not already sustainable forest management practices shaped by non-energy wood sectors. Estonian Forest and Wood Industries Association proposes to revise the document to improve the applicability and preciseness of the document and ease operationalisation of sustainability criteria as follows:
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans) and

27 Nov 2020 · European Green Deal, forest policy and bioenergy