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US Industrial Pellet Association

USIPA

The US Industrial Pellet Association is a trade organization promoting safety and sustainability in the industrial wood pellet industry.

Lobbying Activity

US pellet association demands alignment with existing EU rules

5 Dec 2025
Topic — This consultation reviews technical screening criteria for the EU’s sustainable finance taxonomy.
Message — The organization requests that the EU retain existing sustainability requirements from the Renewable Energy Directive. They argue against introducing additional rules or higher greenhouse gas savings thresholds.12
Why — Regulatory stability would reduce compliance costs and protect access to private investment capital.34
Impact — Taxpayers face higher costs if restrictive rules force energy projects to rely on public financing.5
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US pellet industry urges EU to include biomass in security framework

13 Oct 2025
Topic — The Commission is updating energy security rules to manage geopolitical risks and climate goals.
Message — USIPA requests that biomass be recognized as a reliable and competitive energy source. They propose using transatlantic partnerships to ensure a steady supply of wood pellets. They also advocate for biomass to provide power and heat where electrification is difficult.123
Why — This ensures long-term demand for American wood pellets while reducing regulatory hurdles for exports.45
Impact — Fossil fuel companies lose as coal plants are converted to run on bioenergy.6
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US wood pellet industry urges alignment with existing energy rules

22 Sept 2025
Topic — This regulation establishes methodologies for certifying permanent carbon removal activities like bioenergy capture.
Message — USIPA recommends removing cascading principle and industrial-grade roundwood restrictions to ensure consistency across EU legislation. They also propose replacing the narrow economic viability test for new projects with strategic decarbonization assessments.12
Why — These amendments would lower administrative costs and protect market access for US biomass producers.3
Impact — Traditional timber industries lose priority access to wood feedstock if cascading principles are removed.4
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Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič)

22 Sept 2025 · The state of play of the EU-US relations

US pellet industry urges EU to prioritize bioenergy and BECCS

23 Jun 2025
Topic — The European Commission is revising its strategy for a sustainable and circular bioeconomy.
Message — The association demands the strategy acknowledge bioenergy and carbon removal as central pillars. They want a re-evaluation of biomass availability and enhanced access to international supplies. The cascading use of biomass must remain a flexible guideline instead of a mandate.123
Why — Expanding biomass availability and import recognition would boost US pellet export market growth.4
Impact — Material manufacturers may lose priority wood access if the mandatory cascading principle is removed.5
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Meeting with Sebastian Kruis (Member of the European Parliament)

4 Jun 2025 · US-EU trade relations

US Industrial Pellet Association Urges Wood Residue Exemption

13 May 2025
Topic — Commission review of product lists subject to EU deforestation prevention rules
Message — USIPA requests excluding secondary wood residues from the regulation. They believe treating these residues like waste avoids unnecessary administrative burdens.12
Why — This exemption reduces compliance costs and simplifies tracking for complex international supply chains.3
Impact — Environmental groups lose visibility into the origin of wood used in pellet production.4
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and LP Brussels

6 May 2025 · EU Deforestation Regulation (EUDR)

Meeting with Ilaria Flores Martin (Cabinet of Commissioner Jessika Roswall)

15 Apr 2025 · Bioeconomy

Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen)

8 Apr 2025 · EUDR

Meeting with Roberts Zīle (Member of the European Parliament)

14 Jan 2025 · Industrial pellet industry

US pellet association urges better biomass carbon accounting rules

29 Jul 2024
Topic — The European Commission is updating rules for monitoring and reporting industrial greenhouse gas emissions.
Message — USIPA requests that reporting rules align with renewable energy laws to keep biomass zero-rated for emissions. They specifically seek the inclusion of legal protections for existing projects and remote regions.12
Why — This allows their members to maintain market share by keeping wood pellets tax-exempt.3
Impact — Energy consumers would face higher prices if biomass is treated like fossil fuel.4
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US pellet industry urges EU to value managed forests

11 Jul 2024
Topic — The European Commission is evaluating regulations for carbon emissions and removals from land use.
Message — USIPA requests that policy recognizes the long-term carbon benefits of active forest management. They advocate for including international supplies in biomass estimates to avoid over-rationing.12
Why — This would ensure continued market access for US wood pellet exports to Europe.3
Impact — Energy consumers may face higher costs if the EU restricts sustainable biomass supplies.45
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Meeting with Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius) and Drax Group plc and

6 Feb 2024 · wood pellet and EUDR

US Pellet Association seeks coherence in biomass reporting rules

23 Aug 2023
Topic — Updating rules for monitoring and reporting greenhouse gas emissions under EU ETS.
Message — The association requests full coherence between sustainability standards and carbon reporting rules. They argue for aligning implementation timelines and grandfathering provisions to protect investments. They also seek specific derogations for biomass use in the EU's outermost regions.123
Why — This ensures biomass remains zero-rated, preventing sudden and unintended compliance costs.45
Impact — Consumers and isolated regions suffer from increased costs and stalled decarbonization efforts.67
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Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur) and Bioenergy Europe

11 May 2022 · RED

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)

25 Feb 2022 · RED

Response to European Bioeconomy Policy: Stocktaking and future developments

31 Aug 2021

This submission is on behalf of the US Industrial Pellet Association (USIPA), whose members have been supplying European energy producers with sustainable woody biomass from managed forests in the SE US for over a decade, enabling them to reduce their emissions and deliver on the EU’s climate and energy goals. Bioenergy is a vital part of the bioeconomy and will play a big role in helping the EU to meet its 2030 and 2050 climate objectives. It is already doing so, providing 60% of renewables and is helping to replace the use of coal. Delivering a vibrant bioeconomy, will in part rely on both domestic and imported wood fibre. In 2020, the US exported nearly 7.26m metric tons of sustainable biomass to the EU and UK, primarily from its southeastern states. This volume was independently certified to standards higher than those required by current regulatory requirements. The sale of these volumes supports a vibrant forest products industry, ensuring forests are growing. According to the US Department of Agriculture, wood volumes have increased by 21% since 2000, and southeastern landowners are growing 43% more wood than they remove every year. USIPA members are also at the forefront of innovative sustainable biomass use. Drax, already Europe’s largest single site decarbonization project, has launched the first bioenergy with carbon capture and storage (BECCS) pilot project of its kind in the world. BECCS, now a proven technology, is central to delivering the negative emissions needed to meet our climate targets. The latest IPCC climate report says negative emissions are essential to prevent the gravest impacts of climate change. The IPCC also says technologies that can provide them need scaling up to between 6-10 Gt of CO2 per year by 2050. Granuul, Europe’s biggest pellet producer, with its Sweetwoods project is using sustainable hardwood biomass to demonstrate, on an industrial scale, how novel pre-treatment technology in combination with innovative enzymatic solutions can provide high-quality lignin and wood sugars. To enable the delivery of the EU’s Bioeconomy Strategy the protection and growth of existing wood fibre trade flows and strength of supply chains should be maintained. These flows are particularly sensitive to regulatory decisions, in particular: a.The Renewable Energy Directive (REDII) introduced strict, harmonized, Union-wide sustainability criteria which, together with risk-based forestry certification schemes, underpin the sustainability of biomass produced by our members. The impact legislation has goes well beyond today’s uses of biomass, therefore, we should avoid knee-jerk decision-making to ensure the long-term investment to protect these important supply chains. b.A clear cascading of biomass use is vital to ensuring best use of biomass. This cascading is already being delivered through clear and unambiguous market signals. For example, in the US Southeast high value sawlogs are typically 7 times more expensive than pulp sourced in the same area. The Bioeconomy Strategy must not seek to make this concept rigid, ignoring local heterogenous factors and consequently distorting markets thus reducing supply of sustainable biomass. c.Sustainable biomass end use should always align with the best carbon outcomes, but the EU should not attempt to create an overly-prescriptive hierarchy of best-use that is not globally applicable and does not consider local market factors, leading to unintended negative consequences for the forest and the climate. d.Blanket bans of any kind are blunt policy instruments that do not enable critical SFM as they disregard the fundamental principle that all forests are not the same. e.The Bioeconomy Strategy must recognise the multi-functionality of forests - one of the biggest threats to forests and biodiversity is lost habitats through land conversion, so the economic aspect of forestry is so important to incentivize forest owners to keep forests as forests.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

USIPA welcomes the publication of the draft rules to verify sustainability and greenhouse gas emissions savings criteria in the RED. We note several areas where the draft implementing regulation is not consistent with the language in the RED, which if not corrected, will create significant administrative burden for economic operators and could disrupt the bioenergy market place and sustainable supply chains. We offer the attached specific amendments to ensure alignment with the RED legislation and maintain viable and workable pathways for verification.
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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.

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 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 Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

We welcome the opportunity to comment on the EU state aid review. We recognize the important role that state aid will play in supporting the EU’s transition to carbon-neutrality. Sustainable biomass currently plays a critical role in decarbonisation and will continue to be necessary to the EU’s ability to meet 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 carbon-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. In addition to replacing fossil fuels, biomass supports the further development of wind and solar technologies by providing stable, renewable back-up power during intermittent periods. It can also serve as a sustainable alternative for high-temperature heat production in manufacturing processes, and is currently the only viable pathway to negative emissions (through BECCS), which climate scientists agree will be necessary to keep global temperature increases within 1.5C. Sustainable biomass is a key component to mitigating climate change and reducing emissions across multiple sectors. 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 legislation in the recent recast of the Renewable Energy Directive (REDII). 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 the REDII, which has established agreement, and not upon other legislation such as the EU Taxonomy, which remains contested by a variety of stakeholders. Indeed, we believe the EU Taxonomy should also be based upon REDII and have argued as such through other consultations and avenues.
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Response to New EU Soil Strategy - healthy soil for a healthy life

10 Dec 2020

Thank you for the opportunity to provide feedback on the roadmap for a new EU Soil Strategy, updating the 2006 EU Soil Thematic Strategy to address soil and land degradation and to help achieve land degradation neutrality by 2030. The Biodiversity Strategy for 2030 highlights that it is essential to step up efforts to protect soil fertility, reduce erosion, and increase soil organic matter. This submission is on behalf of the US Industrial Pellet Association (USIPA), representing sustainable woody biomass producers in the US Southeast, as well as others throughout the bioenergy supply chain. We recognise that healthy soils are a key enabler to achieve the objectives of the European Green Deal and believe that the biomass industry, together with the broader forest products sector, plays an important role in reducing erosion and protecting and enhancing soil health and fertility. Sustainable forest management (SFM) promotes healthy forests. Sustainable forest management, an established forestry practice, prevents the spread of wildfires and diseases, promotes healthy forests, prevents erosion, and improves the forest floor and its capacity to absorb carbon. Thinning is a forestry practice which is at the core of sustainable forest management. It improves growth of remaining trees and reduces risk of wildfire and disease by creating open canopies within the forest. 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 and allowing for the forest to support a diverse understory for wildlife habitat. The pulpwood resulting from thinning operations is used by a variety of forest products industries, such as paper and biomass. Markets for forest products create more forests. Markets for forest products are incentivising forest owners to keep their lands forested or to bring new lands under forest management. More forest cover prevent soil erosion, and more forest floor means more carbon absorption. Forest owners' confidence in the market for their wood results in investments in their lands, helping the forest to thrive and carry less risk for disease and infestation. The financial incentive that landowners receive from markets like biomass help them afford replanting and regular forest maintenance. It is also important to note that the biggest threats to forest loss in the US are commercial development and conversion to agriculture. Demand for wood products prevents this forest loss to other land uses and preserves the economic and environmental benefits of the forest. The US Southeast is a trusted partner in forest sustainability. In addition to federal level legislation preventing adverse impacts on air, water, and species, state-level forest best management practices (BMPs) also play an important role in sustainable forestry as they include requirements for forest harvests and management. These BMPs include requirements for preventing soil erosion and run off (for example, riparian buffers).
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Response to Climate change mitigation and adaptation taxonomy

9 Dec 2020

We welcome the intention of the Draft Delegated Acts. Significant investment is needed to mitigate climate change, and it is right that investment is channeled into activities that support these goals. Sustainable biomass, currently responsible for 60% of EU renewable production energy, can and already is making a substantial contribution to these goals. We welcome that the Delegated Act is broadly based on existing EU sustainability legislation using criteria that has been fully scrutinized through the Ordinary Legislative Procedure. However, there remains significant issues in the current draft that threaten to undermine investor confidence and impede the EU’s journey to carbon-zero. We are also aware that the Commission intends to integrate the Taxonomy into other areas, such as State Aid. If Taxonomy requirements are not consistent with existing legislation, they could create investor confusion and unnecessarily designate climate-friendly projects and investments as unsustainable. Sustainable biomass offers a long-term substantial contribution to climate change. Bioenergy (for electricity, heat and CHP) has been classified as ‘transitional’ in the Delegated Act. This is in direct conflict with the Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (the Taxonomy Regulation) which under Article 10.1 clearly states that “generating, transmitting, storing, distributing or using renewable energy in line with Directive (EU) 2018/2001…” and “strengthening land carbon sinks” should be considered a ‘substantial contribution’. Further still, using sustainable bioenergy is a key, strategic, long-term solution, because: • It is flexible and dispatchable, supporting the integration of other intermittent renewables such as wind and solar. • It offers a solution for negative emissions through BECCS technology which needs investment to scale up. • It can offer an alternative to fossil fuels in CHPs and high temperature heat for industrial processes. • It supports the long-term health and viability of forests as it creates a market for wood fiber that is otherwise underutilized by other industries. To ensure that the EU can meet climate goals, additional streamlining with the bioenergy sustainability criteria in REDII is needed in several areas. Bioenergy is necessary in order for the EU to meet its carbon-zero targets. In order to ensure the EU can rely on a steady supply of sustainable biomass, the criteria laid out in the Directive (EU) 2018/2001 on renewable energy must be followed. Placing additional or separate criteria within the Taxonomy creates confusion in the market place, hurting investments and supply chain efficiency. Additional criteria beyond the risk-based approach in REDII can create unnecessary administrative burdens for small private forest landowners. Unrealistic or impractical criteria can move investment away from those that cannot bear the administrative costs of compliance. The following areas in the draft need further alignment with the REDII. Specific recommendations for language changes are outlined in the attached position paper. • Production of heat/cool from bioenergy (4.24 – Annex I) - remove reference to ‘transitional’ • Electricity generation from bioenergy (4.8 - Annex 1) - remove reference to ‘transitional’ • Cogeneration of heat/cool and power from bioenergy (4.20 - Annex 1) - remove reference to ‘transitional’ • ‘Forest management plan’ and ‘GHG balance’ (1.4-1.8 – Annex I) – removal of these references and inclusion of REDII bioenergy sustainability and LULUCF criteria • ‘Whole tree stems’ (1.4 – Annex II) - removal of this reference and inclusion of REDII bioenergy sustainability criteria Further information and recommendations are included in the attached position paper.
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Response to EU Forest Strategy

4 Dec 2020

The Commission is looking to propose a new EU Forest Strategy owing to concerns about increasing pressure on forest ecosystems as a result of climate change, which aggravates other key drivers of pressures such as pests, diseases, extreme weather events and forest fires. It also seeks to take into account a rising demand for wood, forest products and energy, as well as urbanisation and land take. We welcome and support the Commission’s ambition to foresee measures to avoid or correct unsustainable practices and seek the right balance and synergies between the need to increase the forest protection and restoration efforts to achieve the EU’s climate, biodiversity and socio-economic objectives, and believe that the biomass industry has a strong role to play in supporting these objectives. We also welcome the recognition of the economic dimension and that forests can provide new products that replace the intensive fossil-based materials and effectively contribute to a new climate neutral society. 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 ensure best possible implementation of new measures. Biomass for energy can help deliver the goals of the EU Forest Strategy through the following: 1. 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 provide habitats and benefits for a variety of wildlife. Additionally, markets for wood products provide incentive for private, family forest landowners to replant and sustainably manage their lends, leading to increased forested area and wildlife habitats, as well as ensuring habitat connectivity, which is critical to wildlife survival. Thinning, an established sustainable forest management best practice, improves 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. Pulpwood produced from thinning operations is used for a variety of wood products, including paper and biomass. 2. Demand for sustainable forest products creates demand for more sustainable forests. It is vital that any forest product must be sustainably sourced, to ensure the health and growth of the forest and to protect and promote biodiversity. This is why we welcomed the strict, harmonised, Union-wide criteria for biofuels, bioliquids and biomass fuels, also covering imports within the recast Renewable Energy Directive. These criteria, together with risk-based forestry certification schemes, ensure the sustainability of biomass. One of the biggest threats to forests and biodiversity is lost habitats through land conversion. This is why the economic aspect of forestry is so important to ensure that forests stay as forests. 3. Biomass can replace fossil fuels. Biomass has been a success story, removing coal from the energy grid in Europe, and is one of the fastest ways to decarbonize, while also supporting further development of intermittent renewables such as wind and solar. Together with BECCS – now a proven technology being piloted at Drax Power – forest biomass can also help create negative emissions.
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

We welcome the urgent attention that the Commission is placing on 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. As a trade association consisting of US manufacturers and exporters of sustainable woody biomass, we are proud to be playing our part in supporting healthy forests. In particular, we welcome the focus on ensuring no deterioration of ecosystems following their restoration. For this to be happen, it is vital to take a holistic look at the forest both from an environmental point of view and an economic point of view. 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. When looking at nature restoration, 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, ensure that biodiversity and forest health is maintained. The use of biomass encourages forests to stay as forests. Markets for wood products provide incentive for private, family forest landowners to replant and sustainably manage their lands, leading to increased forested area and wildlife habitats, as well as ensuring habitat connectivity, which is critical to wildlife survival. 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, an established sustainable forest management best practice, improves 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 thinnings) for bioenergy, as proposed in the EU Biodiversity Strategy, could have a net negative effect for 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 low paying ability. Restricting the use of whole trees for bioenergy could encourage conversion of forests to monocultures. Furthermore, removing weaker trees ensures that stronger trees are more likely to be the seed trees for the next forest growth resulting in a stronger, healthier forest into the future. The US is a trusted partner in sustainability. 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. 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 landowners 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 Updating the EU Emissions Trading System

25 Nov 2020

Thank you for the opportunity to provide feedback on the inception impact assessment for Amendment of the EU Emissions Trading System (Directive 2003/87/EC). This submission is on behalf of the US Industrial Pellet Association (USIPA), a trade association consisting of sustainable biomass producers in the Southeast US as well as others in the bioenergy supply chain – www.theusipa.org. Negative Emissions Through Bioenergy with CCS (BECCS) The global consensus is that achieving climate neutrality will only be possible with negative emissions, for example through the deployment of technologies such as bioenergy with CCS (BECCS). The current ETS system has shown that creating carbon markets has been an effective tool for reducing carbon emissions. BECCS technology is now a proven technology, with the world’s largest bioenergy producer, Drax Power, trialling a pilot that is already capturing one tonne of carbon per day, with a view to eventually capturing 16 million tonnes per year of negative emissions. We believe that a market mechanism can play an important role in supporting the innovation needed to scale up and deploy negative emissions and we ask that the impact assessment considers this policy option within the framework of the ETS. Zero-rating of Biomass in the ETS The use of sustainable biomass to reduce carbon emissions is underpinned by the zero-rating afforded to biomass in the ETS. There have been misguided challenges to this and concerns of double accounting or a carbon lag or debt. We set out below why the zero-rating for biomass should be maintained. 1. Biomass is part of the biogenic carbon cycle, which recycles carbon in the atmosphere. Carbon is absorbed and stored in wood over its lifetime and is released when burned for energy, and that same carbon is reabsorbed and stored by growing forests. The biogenic carbon cycle is acknowledged by the IPPC, understood by forest and climate experts around the world, and is the crux of biomass’ zero-rating. 2. Biomass supports forest health and growth, leading to increased carbon storage. The US Southeast, one of the world’s largest producers of sustainable biomass, has a forested area larger than the total land area of France, Germany and the UK combined. According to the USDA Forest Service, private forest owners in this region are growing 40% more wood than they remove every year. This is because of the financial incentive from markets for forest products, which encourages replanting and sustainable management of forest lands. At the same time, less than 4% of forest resources in the US Southeast are harvested every year for forest products. In the region our members source from, carbon stocks and forest growth are on an upward trajectory and there is no 'carbon debt' or 'payback period' associated with sustainable forestry so long as this net growth continues. 3. 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. These emissions are reported to regulators in EU Member States, who use these figures to demonstrate compliance with EU and Member State climate laws. These figures have shown that using wood energy in place of coal to produce electricity can reduce carbon emissions up to 90%. 4. 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.
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Response to Land use, land use change and forestry – review of EU rules

25 Nov 2020

Thank you for the opportunity to provide feedback on the inception impact assessment for the amendment of the LULUCF Regulation (EU) 2018/841. This submission is on behalf of the US Industrial Pellet Association (USIPA), a trade association consisting of sustainable biomass producers in the Southeast US as well as others in the bioenergy supply chain - www.theusipa.org The Commission, through the proposed revision of the LULUCF Regulation, seeks to analyse the synergies between LULUCF and other land-related sectors and uses – including the forest bioeconomy. The sustainable wood energy industry can support Commission as it ultimately seeks to tackle the following issues set out in the Inception Impact Assessment, in particular ensuring: i) forests sequester more carbon, ii) biomass supports forest growth , and ii) biomass supports biodiversity and prevent forests fires and pest outbreaks. i) Ensuring forests sequester more carbon. A recent study published in the scientific publication Nature, which was carried out by an international team from 2005 to 2017 and 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, despite an increase of wood pellet exports to the EU. 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 France, Germany and the UK combined. According to the USDA Forest Service, private forest owners in this region are growing 40% more wood than they remove every year. Because demand for a range of wood products provides financial incentive for private landowners to preserve their forests as forests, continue replanting, and sustainably manage their lands, 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 forests fires and pest outbreaks. Sustainable forest management and biodiversity protection work hand in hand. Sustainable working forests carry less risk of fire and disease outbreak, and also have a variety of landscapes and tree ages, each providing habitats and nutrients for a variety of species. Working forests are supported by markets for wood products, such as biomass, which provide financial support for private landowners to make investments in sustainable forestry. When it comes to guaranteeing the sustainability of biomass used to produce energy in Europe, the REDII introduced strict, harmonised, Union-wide criteria for biofuels, bioliquids and biomass fuels. These criteria, together with risk-based forestry certification schemes, underpin the sustainability of biomass produced by our members. With REDII only coming into force in 2018, it would be counter-productive to introduce further measures at this time. Achieving the EU’s increased climate target by 2030 and the climate neutrality objective by 2050 require immediate solutions. Sustainable biomass has proven to be a fast and reliable way to decarbonize the economy thanks to its ability to both replace fossil fuels on the grid and provide stable, on-demand, back-up power to support deployment of other renewable technologies. Furthermore, bioenergy with CCS (BECCS) is now a proven technology in the power sector and is in the process of being scaled up to help deliver negative emissions.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

USIPA supports the initiative to increase the EU’s climate and energy targets for 2030, and to increase the share of renewable energy in final energy consumption. This will better prepare the EU for the transition towards climate neutrality by 2050. Consequently, some existing EU legislation may need to be reviewed and updated to ensure that it reflects this increased level of ambition. We must ensure that renewable energy sufficiently contributes to the achievement of the higher EU climate ambition. In that context, we would like to recall that sustainable biomass is already the largest renewable energy source in Europe. Sustainable biomass is, without a doubt, a key technology to achieving the EU’s climate goals by 2030, 2050, and beyond. When it comes to guaranteeing the sustainability of biomass, the REDII introduced strict, harmonised, Union-wide sustainability criteria which, together with risk-based forestry certification schemes, underpin the sustainability of biomass produced by our members. The use of sustainable biomass is key to decarbonising the EU and risks of using unsustainable biomass have been addressed by both policy and industry. Informed by extensive debate over many years, regulators and certification systems have recognised these risks and have put in place sustainability requirements to control them. These include EUTR (due diligence on legality of wood procurement), the RED, and the specific sustainability requirements in different member states (MS). In addition, in 2019, 61% of industrial pellet consumption in the EU-28 was certified by the Sustainable Biomass Program (SBP). It is also important to note that REDII came into force in 2018 and MS have until 30 June 2021 to transpose most of its provisions. Extensive work is underway by MS’ administrations to transpose the RED. Therefore, the Commission has to balance the need to amend REDII and achieving results through other means – such as providing additional guidance and allowing MS the time to transpose the measures and assess their effectiveness in due course. Therefore, among the options available to fulfil the objectives laid out in the roadmap, option 5, consisting of a combination of options 2, 3 and 4 would be the best way forward. We believe it is possible to encourage reductions in supply chain emissions without using regulatory measures. Options could include training programmes on value chains to increase their efficiency, facilitating workshops within the industry to share best practice in emissions reductions and non-binding transparency disclosures (e.g. guideline or platform to share best transparency of logistics). In terms of amending REDII in line with the 2030 Climate Target Plan and the EGD, we urge the Commission to not amend articles 29 – 31 as these introduced strong measures which have not yet been transposed by MS. Revising these articles now undermines the 2 year legislative process and debate that took place in order to finalize the REDII, which included extensive, international stakeholder input. Additionally, regulatory certainty is critical for investor confidence and increased deployment of renewables. Revising this legislation before it has been implemented sends mixed signals to the industry and hurts investor confidence, making it more difficult for the EU to source sustainable biomass and meet climate goals. The roadmap mentions that “The risk of unintended incentives for using unsustainable biomass will be assessed and minimised through appropriate safeguards.” As long as the provisions introduced by REDII, especially the sustainability criteria for biomass, are properly transposed and implemented by MS, there will be very low risks of using unsustainable biomass. We urge the Commission to continue its dialogue with the industry who have been meeting the criteria set by REDII and take their input into account when considering the need for such safeguards.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

RE: USIPA response to the inception impact assessment of the Energy Efficiency Directive This submission is on behalf of the US Industrial Pellet Association (USIPA), a trade association bringing together over 30 members based in the southeastern US, representing all aspects of the wood energy export industry and supply chain, including wood pellet producers, large landowners, traders and brokers, equipment manufacturers, bulk shippers and service providers. We welcome in particular the stated ambition that increased energy efficiency will help reduce air pollution for the benefit of public health. However, we wish to respond to the reference to biomass combustion as a main cause of air pollution, and want to ensure that the Commission recognizes that solid woody biomass that has been optimized for large-scale energy production greatly reduces emissions of both carbon and of harmful pollutants such as NOX, SOX, ash, and sulphur when compared to fossil fuels. Wood pellets, a form of solid biomass used to produce large-scale heat and energy, are dried and compressed during production to remove moisture and ensure maximum efficiency. Wood pellets are graded and standardized through ISO 17225, which has required limits for moisture content, ash, and fines, and requires a high calorific value. For US biomass producers, this standardization is required within contracts with European power generators, and is mandated and expected by the marketplace. It is important to note that this type of biomass for energy production is markedly different than the burning of greenwood or logs for fire, which can have up to 50% moisture content. Additionally, on this side of the Atlantic, USIPA members employ modern pollution control technology at pellet production facilities, and comply with all US state and federal laws including the US Clean Air Act. US pellet producers meet air quality regulations in each of their operations, and many invest in upgrades to exceed what is required by those regulations. We ask that when the Commission looks at air pollution, it does not put biomass-for-energy combustion on par with general biomass burning or with fossil fuel combustion as it appears in the roadmap. Contact: Jessica Marcus, VP of Policy – JMarcus@theusipa.org Transparency Register #227344812892-07
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

11 May 2020 · Green deal, climate and energy policy

Response to Climate change mitigation and adaptation taxonomy

17 Apr 2020

Thank you for the opportunity to provide feedback on the Commission Delegated Regulation (DR) on a climate change mitigation and adaptation taxonomy. The US Industrial Pellet Association (USIPA) is a trade association promoting sustainability and safety practices within the US wood energy industry. We advocate for the wood energy sector as a smart solution to climate change and we support renewable energy policy development around the globe. Our members supply wood pellets for large-scale, low-carbon heat and power production across Europe, in particular to the Netherlands, Belgium, Denmark and the UK. USIPA welcomes the Commission’s initiative to set out a framework to define environmentally sustainable economic activities for investment purposes through the Taxonomy Regulation (TR). However, we believe that the timing, as well as the limited duration of this call for feedback on the DR – only 4 weeks in the middle of the coronavirus outbreak - do not ensure the proper consultation of stakeholders and will lead to ineffective law making. Given the novelty and complexity of this initiative, we urge the Commission to align the technical screening criteria with existing EU legislation. In some instances, such as the sustainability of biomass used for energy, harmonised, Union-wide criteria have recently been agreed in the RED II and are being put into law. A proportionate impact assessment to accompany this initiative is key and should demonstrate convergence with the existing legislative framework. As the TEG’s recommendations will constitute the basis for the Commission’s work in drafting the current DR, we would like to draw attention to the fact that the TEG seeks to introduce criteria which are unnecessarily stricter than any existing legislation or standards, and also go beyond any available certification or verification system in existence. We believe that unrealistic and impractical criteria risk diverting investment away from activities which are considered sustainable by other legitimate standards. When it comes to forestry, in order to demonstrate climate change mitigation, the TEG proposes 3 cumulative criteria which are not only inconsistent with RED II, but no forestry certification to date can ensure compliance – not even the FSC Forest Management certification, considered to be the gold standard for forestry. What is more concerning is that the technical annex then goes on to disqualify the RED II risk-based approach, instead requiring a verified GHG balance for each individual forest area. This requirement will create unnecessary administrative burden for biomass supply chains, which source a smaller proportion (of lower-value material) from a large number of individual, privately-owned family forests. These requirements are made even more impossible where biomass is made from sawmill residues. Inconsistencies in the TEG’s recommendations risk to lead to impractical rules. For instance, for the production of electricity from bioenergy, a GHG emission reduction limit of 80% compared to the fossil fuel comparator in RED II is not, as suggested by the TEG, equivalent to 100g CO2e/KWh. Moreover, the problem with introducing a technology agnostic emissions threshold for all electricity generation is that it assumes all generation to have the same utility/value. However, biomass can directly replace coal, provides a dispatchable source of renewable energy and offers additional services to the grid which cannot be delivered by variable sources of electricity generation, including flexibility, balancing, and security of supply, among others. We call on the Commission to set up the Platform on Sustainable Finance as soon as possible, according to article 15 of the TR, ensuring that its composition is representative for all stakeholders. As required by the TR, we urge that prior to adopting the delegated acts, the Commission gather all necessary expertise from the Platform regarding technical screening criteria
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Response to 2030 Climate Target Plan

14 Apr 2020

Thank you for the chance to provide feedback on the inception impact assessment for the 2030 Climate Target Plan Communication. This submission is on behalf of the US Industrial Pellet Association (USIPA), a trade association bringing together over 30 members based in the southeastern US, representing all aspects of the wood energy export industry and supply chain, including wood pellet producers, large landowners, traders and brokers, equipment manufacturers, bulk shippers and service providers. USIPA promotes sustainability within the wood energy industry and advocates for the wood energy sector as an effective solution to climate change. USIPA members have been supplying European energy producers with sustainable woody biomass from managed forests in the southeastern US for over a decade, enabling them to reduce their emissions and deliver on the EU’s climate and energy goals. Converting a power plant from burning coal to burning biomass is a fast, reliable and proven way to decarbonise large-scale energy and heat generation, while also ensuring a just transition to a low-carbon economy. USIPA supports this Commission initiative to increase the EU’s climate target for 2030 from at least 40% to at least 50% and towards 55%, as well as to increase the share of renewable energy in the final energy consumption in 2030 from the current EU level target of 32%. This will better prepare the EU for the transition towards climate neutrality by 2050. We believe that sustainable woody biomass from Southeast US has a crucial role to play in delivering on this renewed ambition. According to Eurostat, sustainable biomass is already the largest renewable energy source in Europe. Biomass provies low-carbon grid stability to intermittent generation capacity which enables further renewables deployment, while also removing coal from the grid. With the help of sustainable woody biomass from Southeast US, the new climate target is deliverable in the next 10 years and will be achievable in a cost-effective manner. Europe has historically been a net-energy importer, and sustainable wood energy imported from the US Southeast can play an important role in substituting fossil fuel imports and supporting the development of low-carbon energy systems. Wood energy has already proven itself to be an effective and long-term climate solution. For example, some USIPA members have engaged in long-term delivery contracts of woody biomass for energy production until post-2040. Beyond traditional power generation, woody biomass can be used to decarbonize other sectors by providing low-carbon heat and steam for manufacturing, as well as for feedstock in the production of bioplastics and biochemicals. USIPA and our members can guarantee the availability of sustainable woody biomass in the US Southeast to deliver on the EU’s climate and energy goals. The US South has 1.1 million km2 of forested land – an area larger than the total land area of France, Germany and the UK combined. Only a small fraction of forest inventory in the US Southeast is harvested yearly for forest products and the region has an annual growth to drain ratio of 1.8, not only resulting in increased forest inventory, forested land, and forest carbon stocks, but also providing growing habitats for wildlife and biodiversity. According to the USDA Forest Service, private forest owners in this region are growing 40% more wood than they remove every year. Wood energy is just a small part of the overall US forest products sector - the biomass industry uses less than 0.1% of total forest inventory in the US Southeast each year to produce wood energy and less than 3% of the total wood harvested each year is converted into pellets. Together with nascent but proven technologies such as BECCS (bio-energy with carbon capture and storage), sustainable wood energy from the US Southeast can realize negative emissions and support Europe’s goals of achieving net zero by 2050.
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Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan) and Edelman Public Relations Worldwide

24 Feb 2016 · Forestry & Biomass