Southern Environmental Law Center
SELC
The Southern Environmental Law Center (SELC) was founded in 1986 as a nonprofit public-interest law firm and operates under the direction of an executive director, corporate officers, and a board of trustees.
ID: 157132415832-83
Lobbying Activity
Response to Revision of the Renewable Energy Directive (EU) 2018/2001
20 Sept 2020
Please accept the attached feedback on the EU Commission's impact assessment for revisions to the Renewable Energy Directive (REDII) from the Southern Environmental Law Center. We support Option 4 of the assessment and further call for the exclusion of forest-derived biomass from the REDII.
Read full responseResponse to 2030 Climate Target Plan
14 Apr 2020
The Southern Environmental Law Center appreciates the opportunity to comment on the EU Commission’s impact assessment on the 2030 climate target plan. Our response focuses on the need to properly account for woody bioenergy emissions as the EU moves forward with its 2030 climate target plan. Additionally, the current assessment must move beyond the existing framework to reflect the broader ambition of the European Green Deal to cut pollution, restore biodiversity, and create a healthy and just society for European citizens. All of these goals are undercut by the continued reliance and subsidization of woody biomass for electricity.
EU climate policies, and the national policies and subsidies that stem from them, incorrectly categorize all bioenergy as carbon neutral at the point of combustion. But leading scientists have shown that burning trees for electricity is as bad for the climate as coal. Even EASAC warned about the serious mismatch between bioenergy science and policy in the RED.
Per unit of energy, biomass plants emit more carbon from their smokestacks than coal, and any carbon “benefit” is hypothetical and occurs, if at all, decades to a century later—and then only if forests are allowed to regrow and are not converted to plantations or recut for energy. In recognition of this, in 2018, the UK set a substantially lower limit on fossil-fuel lifecycle CO2 emissions from biomass fuels in order to qualify for renewable energy subsidies, a limit that appears impossible for wood pellets to meet. And, in 2020, the UK proposed to exclude new coal-to-biomass conversions from future rounds of its Contracts for Difference scheme.
A 2018 EU Commission report also highlighted that energy scenarios with reduced bioenergy use and greater reliance on wind and solar resulted in the lower carbon emissions. Support for biomass is therefore incompatible with the EU’s plan to drastically reduce GHG emissions by 2030 and reach climate neutral by 2050. The EU’s climate policies must be strengthened to accurately reflect the full lifecycle emissions of bioenergy feedstocks, taking into account both direct and indirect land-use change impacts.
Not only does burning biomass emit large amounts of carbon, but cutting down trees for that process simultaneously reduces the ability of forests to sequester more carbon. Although the EU’s forests are a net sink of CO2, the forests’ capacity to remove carbon from the atmosphere has been significantly declining since 2015 and this trend is set to continue. The EU must focus on increasing natural sinks, by protecting and restoring natural forests and avoiding the additional pressures on these ecosystems from bioenergy demand.
The EU incentives for woody biomass also undermine the EU’s broader efforts to protect biodiversity and the EU’s “do no harm” principle. A 2016 EU Commission report recognized the “direct negative ecological consequences” of much of the bioenergy sourcing occurring in the southeastern US. This sourcing has been shown to include clearcutting of highly biodiverse forests and the use of large-diameter whole trees. Biodiversity loss and climate change are inextricably linked. The EU must therefore consider what impacts its climate policies will have on global biodiversity and should set specific criteria on how to minimize and reverse biodiversity loss as a key component of climate adaptation and mitigation.
Unfortunately, the 2018 REDII failed to introduce meaningful restrictions or safeguards for bioenergy. Continued support for bioenergy can no longer be justified on climate or environmental grounds. The EU’s must re-evaluate REDII’s continuing reliance on bioenergy in light of the climate, biodiversity, and other environmental harms from large-scale bioenergy use. The EU must end subsidization of this industry and focus instead on truly clean and renewable energy sources like wind and solar, as well as the protection and restoration of forests and other natural carbon sinks.
Read full responseMeeting with Juergen Mueller (Cabinet of Vice-President Karmenu Vella) and Stichting BirdLife Europe and
11 Feb 2015 · Biomass sustainability