REDIII: Valuing the maintenance of carbon sinks and ecosystems over using biomass for energy?

Bioenergy and the reliance of biomass sources, is expected to play a crucial role in delivering the European Green Deal and in decarbonising the energy system to support achieving climate neutrality by 2050. But how sustainable is it, and what are the implications of revised Renewable Energy Directive (RED III)?

Bioenergy and the reliance of biomass sources, is expected to play a crucial role in delivering the European Green Deal and in decarbonising the energy system to support achieving climate neutrality by 2050. But how sustainable is it, and what are the implications of the upcoming revision of the Renewable Energy Directive (RED III)?

In early May (2021) a draft of the Renewable Energy Directive III was leaked providing insight into policy options to increase EU renewable energy efforts and more sustainable use of biomass. The draft confirms the EU’s aim to source 38-40% of its energy from renewable sources and proposes updates to the bioenergy sustainability criteria.

The RED III revisions follow a need to better align with and reach the objectives of the Green Deal and the 2030 Climate Target Plan of 55% emission reduction. Further, it implicitly recognises that biomass use is not sustainable by default, and that sustainability criteria are a necessary tool to mitigate the risk of unsustainable use of biomass in the EU. Even if labelled as renewable, biomass resources are functionally finite (in that they need time to regrow or recover) and cannot be harvested at scale without impacts on the ecosystems from which they are extracted, or the climate to which they are intended to contribute.

Understanding what sustainability means in practice and how it is reported is another challenge for good and effective policy. Under the LULUCF Regulation (revision expected for the second quarter of 2021), biomass used to produce energy is technically ‘zero carbon’ rated, as the emissions from forest harvesting have already been accounted for in the forest sector.

One of the issues central to the sustainability of bioenergy is the time difference between the emissions of carbon at the point of combustion and the removal of atmospheric carbon through the past growth and assumed future growth associated with the supply chain for the feedstock – commonly referred to as the carbon debt period. Whilst the LULUCF accounting system may ‘balance the books’, what the atmosphere sees is different, and the time of emissions and removals varies. If the climate were stable, this may not be such an issue. However, with an urgent need to halt emissions now before further tipping points are realised, the zero-counting of forest biomass before it has had time to regrow presents real risks to miss the EU’s climate targets – and the contribution to real emission reductions in the short term. These are additional to the ecosystem impacts of bioenergy feedstock production.

Whilst the upcoming revised LULUCF regulation is expected to include ways to reduce the carbon debt problem, the leaked REDIII draft provides updates to strengthening the sustainability criteria for the use of solid biomass for power and biofuels for transport – addressing the other forms of emissions and impacts from biomass use. Woody biomass has received particular attention in the RED III draft, due to its substantial and increasing contribution to the EU bioenergy consumption and carbon balance. Strengthening of the bioenergy sustainability criteria are introduced in the draft by:

  • Applying existing agricultural biomass no-go areas to forest biomass, e.g., from primary forests and old-growth forests, meaning that it will no longer be possible to utilise biomass from these important carbon stocks to count towards RED targets;
  • Applying criteria to small-scale heat and power installations below a total rated thermal capacity of 20MW and therefore expanding the range of users of biomass; and
  • Possible national caps on the use of stem wood above a certain size for energy purposes.

It is essential that both carbon and ecosystem impacts are well addressed for biomass to have any substantial role in the EU’s decarbonisation agenda, and both need to be more stringent than currently in RED II. This is particularly important as bioenergy is still foreseen as playing a substantial role in decarbonisation pathways to 2030 and 2050, as highlighted in the newly released IEA Net Zero 2050 report. Importantly (according to Carbon Brief) the IEA’s transition pathways including biomass used for energy reaches net-zero “earlier than the large majority of IPCC pathways, due to the IEA’s decision to balance emissions from energy and industry without relying on offsets from land or forests” signalling the importance of maintaining land carbon sinks.

Taking forward sustainability criteria for biomass in the EU has always been a challenge, with competing demands for biomass placing sustainability competence in different policy files, including agriculture, forestry, bioeconomy and renewable energy. From the leaked REDIII proposal, it seems that there is a move towards recognising the carbon implications of using biomass for energy when there are other ways in which forest and agricultural land can contribute to mitigation. This is coupled with a recognition of the improvement and roll-out of alternatives for energy generation, even in decentralised and rural economies that do not need to rely on biomass for combustion.

Promoting the idea towards a focus on utilising biomass sustainably within a circular bio-economy would help to reduce the material footprint of the EU economy which will have far-reaching implications for sustainability in general, driving forwards decarbonisation in the EU beyond what can achieved with a focus on renewable energy alone. Decisions on the REDIII final text should consider the inclusion of criteria that maintain carbon sinks (as they partly do) and prioritise material use through a hierarchical approach over energy generation, similar to that proposed in IEEP’s own 2050 net-zero report on agriculture (page 7).

Only time will tell, but a lot of eyes will be looking at the official REDIII draft which is expected to be presented on 14 July as a part of a broader package (‘Fit for 55’) of laws intended to meet the EU’s updated climate targets for 2030.