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Svenska trädbränsleföreningen

Svenska Trädbränsleföreningen är branschföreningen för svenska producenter av brännved, flis, skogsindustiriella biprodukter som spån och bark, returträ, pellets, briketter, och träpulver.

Lobbying Activity

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

The Swedish Wood Fuel Association welcomes the Commission´s initiative to review the EU renewable energy rules to contribute to a higher climate ambition as part of the European Green Deal. We support the target to increase the share of renewable energy in the energy consumption from 32% to 40% by 2030. However, we want to raise some major concerns regarding the amended sustainability criteria for forest biomass that will hinder the use of biomass for energy and thus prevent reaching the EU goal of ruling out the use of fossil fuels. The suggestions are contra productive for tackling the climate crisis and the fuel security in EU. All possible solutions need to be mobilized and compiled on an equal footing, adhering to the principle of technological neutrality, to help to slow down warming, and notably all the bioenergy from biomass. Biomass is the main source of renewable energy in the EU. The market actors needs stable and predictive in EU policies. The implementation of the latest Renewable Energy Directive (RED II) has just started and the Commission has not yet published the guidelines on sustainability criteria. Possible amendments on these criteria should be considered only after implementing and evaluating the current directive. Constant changes on the sustainability criteria do not support creating new investments in a sustainable energy production and wood-based innovations. It should be acknowledged that wood bioenergy is largely based on residues and wastes from logging and timber processing and low-quality wood. The market ensures that high-quality timber is used for high-value added products. This is also reflected by the market actors. The Commission is proposing to regulate cascading use of woody biomass with an additional delegated legal act, contrary to the rules of the market economy. Regulating the cascading principle in the EU Renewable Energy Directive would destroy the bioenergy sector and have direct negative effects on forestry. This mandatory approach in the proposal for a directive, which is harmful to the market economy, is something that we therefore firmly reject. In this context, the question arises why the Commission would like to introduce obligations regarding the cascading principle for climate-friendly renewable raw materials and not for climate-damaging fossil raw materials. The objective of the “Fit for 55” package is the rapid phasing-out of the climate-damaging fossil fuels coal, crude oil and natural gas, and not the phasing-out of biomass. Consequently, the Commission should present a proposal for cascading requirements for oil or natural gas. We also have strong concerns about the proposed changes regarding the risk-based approach. The new entries on biodiversity and soil quality introduce new requirements in a rather general way (e.g “degradation of primary forests”, “vulnerable soils” or “large clear cuts”) which have not been defined. As a result, it will be very challenging for national forest legislations to comply with these requirements. This new risk-based approach would thus require regulatory changes in Member States and create a large amount of bureaucracy for forest owners who should start reporting sustainability on a forest holding level. In this context, the EU should stick to the risk-based approach decided in RED II in 2018. Also, we don’t support he Commission´s initiative to apply no-go areas on highly biodiverse forests given that this terminology is based on undefined terms, leaves too much room to interpretation, does not provide measurable or scientifically based criteria and is too broad to be used in practice in a way that would be relevant for all forest types. If needed, this terminology should be defined and clarified at national, regional, and local level. EU-wide and undefined terms could risk the availability of wood biomass for energy by excluding several forest holdings performing sustainable forest management and related bioenergy production
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Response to Land use, land use change and forestry – review of EU rules

8 Nov 2021

The Swedish Wood-Fuel Association welcomes the Commission’s recognition of the LULUCF sector’s contribution to mitigate climate change. Since 1990 both the forest area and the volume of growing stock have continued to increase in all regions in Europe. The sector is one of the most important sectors in the Green Deal and the only sector that can produce green circular biobased products and energy. This is done by sustainable forest management that provides both an active carbon sink and biobased material that can phase out non-renewable and fossil materials. However, we see a risk that the proposed sink of 310 million tonnes of CO2 will put too much focus on the potential of forests as a sink instead. This will lead to lower harvest levels and less available bioenergy and biobased products. We see a clear risk that the high goals for the carbon sink will both affect the forest policy in member states (that is national competence) and also compensate for fossil emissions in sectors that are slow in their conversion from fossil products and energy. The focus of the LULUCF-regulation should be on active sustainable forest management. Thereby ensuring a vital and secured sink over time. Keeping a large carbon storage in old forests with high biomass is a risky approach in a changing climate.
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

Comments on the operational guidance to RED II implementation The Swedish Wood Fuel Association points out the fact that forest biomass is the most important renewable energy source in the EU27 (Eurostat) and the effective utilization of sustainably managed forests in the EU will be in future very important to fulfill the aims of the Green Deal and the Paris climate agreement. The operational guidelines suggested by the Commission which are key to implement RED II sustainability criteria. We understand the time pressure which the Commission is working with when looking ahead for July 2021, the start of the RED II implementation but the MS and bioenergy industry can’t wait for implementation guides delivered so close to the implementation of the directive. The Swedish Wood-Fuel Association are very concerned that on certain aspects the implementation guideline goes beyond the Directive’s competence and could therefore raise issues regarding Member States competences. We would emphasize the minimizing additional administrative burdens on forest owners and ensuring stable framework conditions for necessary investments in the bioenergy sector in order to meet the ambitious energy and climate goals. During 2020 the RED II BIO project report was under public consultation. It contained an analysis of national level compliance for EU MS and some other countries. We regret that this report was not published in time to provide stakeholders background information which would help assessing this guidance text. The regulations should stick to the same definition for forest biomass as the Directive it is meant explain. The regulation differentiates between “primary biomass from forests” and “secondary biomass from forests” while the directive uses “forest biomass” and “residue”. The regulation refers to in art 3 to four different forest categories: primary forests, natural forests, semi-natural forests, plantation forests. Only the last 3 are defined. It is not clear where these specific definitions come from. If it is expected that all forest can be classified in these types, the requirement in art 3 para 1.b.ii will be limiting for forest regeneration. We recommend using FAO definitions forest types. Please avoid mixing up “plantation forests” with “planted forests”. The implementation regulations should stick to the five sustainability requirements set in point (a) of Article 29 (6) of Directive (EU) 2018/2001. Especially we have trouble with art 3, para 1.b.ii and art 3 para 1.b.iv. The article 29, 6 a ii of the RED II refers to “forest regeneration of harvested areas” and relates only to the re-establishment of a forest stand by natural or artificial means following the removal of the previous stand by felling or as a result of natural causes, including fire or storm. Adding the requirement above in para 1.b.ii is adding a biodiversity angle, which is not the intention in the directive, The article 29, para 6.a.iv of the RED II refers to “maintenance of soil quality and biodiversity with minimizing negative impacts”. Adding regulation of the removal of stumps, roots, deadwood and where appropriate, needles or leaves to this regulation is too detailed. For both points the above-mentioned provisions of the guidance are going very much deeper level than in the RED II regulation text and is jeopardizing the role of Member States to explain and show how RED II requirements are covered by national legislation. Such details are rather subject to practices and operational guidelines. We would therefore suggest deleting these detailed level texts. It is unclear what “clear-cuts are minized” under art 4 1.b.iv. means (the amount, the area, the size, the responsibility to define what “minimization” means). This minimization and falling of the A-level assessment may paralyze the harvesting operations where bioenergy collection is a side product. We are concerned that this is a result of the toxification of the renewable energy debate.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The Swedish Wood-Fuel Association is an organization for Swedish producers of solid wood fuels within the forest and recycling industry. We see that bioenergy is an essential key to leave the fossil dependence. Recent European Commission strategies underline that sustainable bioenergy is “a win-win solution for energy generation” (COM(2020) 380 final, EU Biodiversity Strategy 2030, p.10) and count on an increased mobilization of waste and residues for bioenergy generation to achieve a smart sector integration (COM(2020) 299 final, p.6). The achievement of the 2050 carbon neutrality goal will also depend on bioenergy generation. Sustainable bioenergy will still be the largest renewable in 2030 in the EU, standing at the forecasts included in the Integrated National Energy and Climate Plans. The Swedish Wood-Fuel Association welcomes the ambitions in EU to reach for sustainability and climate neutrality. This proposal will however not lead EU in that direction. The delegated acts are not taking in consideration the possibilities of EUs growing forest and the potential in substituting fossil products and energy. Also, EU is heavily depending on import of natural gas, oil and coal. We think that is unacceptable that natural gas (a fossil fuel) get a free-ride in the short term. Bioenergy is one of the largest key players to get rid of fossil dependency, both in transport, heating/cooling and industry processes. Bioenergy is not a temporary solution. Renewables must work together in a modern and flexible energy system. Forests are national competence within EU. The proposed requirements are not taking this in consideration. The requirements are very detailed, and we would like to point out that increased administrative requirements do not add any climate benefits per se. The Commission has not formulated the criteria in line with the revised Renewables Directive (RED II), as required by the legislators. We also think that it would have been more appropriate to use the definition of sustainable forestry as defined by Forest Europe. Forest Europe is the political high-level forum for dialogue and cooperation on forests in Europe (https://foresteurope.org/). Under Afforestation (1.4 Annex II) we suggest removing reference to use of whole tree stems for bioenergy. “Whole trees” is an arbitrary categorization that can refer to high or low value trees in a variety of sizes. Arbitrarily excluding some low-value feedstocks have no practical implications on forestry practices as thinnings are mainly done in order to maximise the quality timber production. These small diameter "whole trees" can be considered as residues of timber production. Deviations from the principle of technology neutrality have been made, e.g. in terms of renewable energy, forestry and buildings. Also, the taxonomy is disproportionally favoring electrification and hydrogen. We see an urgent need that the Commission clearly states that research, development and innovations in the bioenergy sector contribute substantially to climate change mitigation. When excluding “transitional activities” and categorizing bioenergy solutions as transitional activities in other parts of the taxonomy, the conclusion is that the Commission does not see research, development and innovation in bioenergy as a sustainable activity. This is totally unacceptable and not in line with Horizon 2020 and Horizon Europe. Last, we would like to point out that we have significant concerns about how the process for this delegated act has been carried out. The lack of sectoral involvement can be seen in the complex and non-relevant criteria.
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Response to EU Forest Strategy

4 Dec 2020

The Swedish Wood-Fuel Association is an organization for Swedish producers of solid wood fuels within the forest and recycling industry. We see that bioenergy is an essential key to leave the fossil dependence. In Sweden have the oil dependence decreased from 75 % in 1991 to 25 % today. This has been possible thanks to mainly bioenergy. Bioenergy is one of the products that forests deliver to the society. We think that the focus of the roadmap is to narrow and is missing understanding of the whole value chain of forests and forestry. It does not take consideration to the development of a circular bioeconomy. Forests take up carbon, store carbon in trees and further into energy and products. This is a circular process compared to the use of fossil raw materials that add extra carbon to the atmosphere. The perspective should be on sequestration, storage and substitution and on how these processes can be enhanced through active sustainable forest management. We think that all three aspects of sustainability should be included. The strategy should be stand-alone from other strategies. We do not agree that the strategy should be based on the Biodiversity strategy. By doing so, only a minor part of all sustainability aspects is included. The Strategy should be the key tool to make forest impacting policies work in the same direction. It should create an enabling framework conditions that does not hamper the implementation of sustainable forest management at national level which is a national competence. The Roadmap is ambitious, and it has many objectives. However, the legal basis for so many various objectives is unclear. In the “problem that the initiative aims to tackle”, the roadmap does not mention directly forests as the producer of wood, which is the most climate friendly raw material. The roadmap also needs to highlight the importance to maintain and strengthen motivation of forest owners and managers to manage their forests furthermore. Instead the good work the forest owner is doing every day should be acknowledged. Finally risk management should be incorporated in the management of forest areas. We have strong concerns about the call “to foresee measures to avoid or correct unsustainable practices » which implies that forests are not sustainably managed. Clear definition of “unsustainable practices” based on sound information should be provided before making such call. We do not understand the call “to strive to decrease the loss of forest coverage” given that EU forest coverage has been increasing for decades. A definition of “last remaining primary and old growth forests who may need strict protection” should be provided We would like to point out the Commission to build on Council conclusions (11/11/20) European Parliament Resolution (8/10/20) which are calling to take a holistic approach to address forests and their multi-functionality, to build on SFM as defined under Forest Europe and to respect the distribution of competences between the EU and Member States
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Comments from The Swedish Wood-Fuel Association We strongly recommend not to open a revision of the RED II. It was adopted not long ago after thorough negotiations. The directive has not yet been implemented in the members states. It will cause uncertainty for the markets actors if the directive should be revised at this stage. Article 29-31 should not be changed. The market needs stable and long-term policy instruments for making the transition to renewable energy. Policy instruments should in general be neutral in technology and let the market and consumers decide on the best solution. Therefore, should detailed regulations be avoided. This will result in the most cost-effective solutions. Also cascading principles causes non-optimal solutions for the market and the EU citizens. Instead general instruments like emission trading and carbon tax will reduce fossil emissions in a cost-effective and market-oriented way. Bioenergy is the largest domestic EU energy source. Only 5 percent is imported. Bioenergy have a great potential to increase energy independence and at the same time create jobs in the whole of EU, also in rural areas. B. Objectives and Policy options. Option 2 Non-coercive instruments such as education, and information can be good if it is carried out in a cost-effective way. Option 3 Option 3 means that the ambition for greenhouse gas reduction will be sharply increased to 50 to 55 % by 2030 and that parts of REDII (Articles 3, 23, 24 and 25) will be revised to cope with the increased level of ambition. The Swedish Wood-Fuel Association doubts that it is possible and appropriate to achieve the target of 50 to 55% with the policy instruments mentioned in section A. In order to achieve the proposed target levels, we believe that a higher degree of general environmental management needs to be used. Option 4 Option 4 means that large parts of RED II are revised (Articles 7, 15, 23, 24, 25, 27, 29, 31) so that they can be used for legal action to implement actions proposed in other strategies within EGD. We do not have a total overview of all other strategies within EGD. We must therefore abstain from commenting further on Option 4. However, we fear that there may be several different requirements and ideas for control. In that case, EGD risks leading to a very complex, difficult-to-understand and cumbersome whole. We can only repeat that we believe that EGD should to a greater extent rely on more general instruments than what appears from the document Inception Impact Assessment. Option 5 Option 5 means opening for combinations of Option 2, 3 and 4. We refer to what has been said above for each option. We advocate general policy instruments like emission trading and carbon tax instead of detailed government of the market. With an increased supply of domestic European renewable energy, production will to a large extent take place in small and medium-sized enterprises, as the document describes in section C. Significantly more jobs will be created in Europe. To enable such a positive development, it is important that new requirements do not lead to increased administrative work in small companies (with, for example, certification). We want to emphasize the importance of what is said last in section C of the document: "This initiative will aim to reduce administrative burdens… ..". We have above devoted a large part of its comments to the issue of Better Instruments. We believe that governance must be based on driving forces for market economy combined with environmental governance instruments with simple design and general application. For example carbon tax and emission trading.
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