EUSTAFOR’s response to the revision of annex V & VI of the Renewable Energy Directive

EUSTAFOR has responded to the public consultation on the proposed Revision of Annex V & VI of the Renewable Energy Directive.

EUSTAFOR supports continuous evaluation and updating of the methodology to accurately reflect reality, including the latest scientific evidence, and thus positively impact the mitigation of climate change. That being said, we have pointed out several points that we feel could disproportionally affect the market.

1. The gap between typical values and default values has increased, which is not supported by the JRC study. With the gap between actual values and default values widening, power plants are still forced to go with their own calculations and use actual values. This undermines the original intention of this system and goes against the Commission’s goal to simplify EU reporting requirements. EUSTAFOR would advise the Commission to follow the findings of the JRC report and stick with the original correction on default values.
2. The new factor for storage requirements is not properly thought through. EUSTAFOR would like to know which factors are considered in the development of the 1.15 C-stor factor, on which study this was based and what the definition of proper storage is.
3. The assumed percentage of moisture in biomass, on which the Commission’s default value calculations are based, is 30% for woodchips. The actual moisture content fluctuates depending on tree species, weather conditions and time between processing and incineration, but typically lies higher. EUSTAFOR suggests using a moisture percentage range that can be used in the calculations, similar to the system used for calculating the impact of transport distances.

The Commission seems to promote investments in renewable energies, but discourage the use of biomass for energy production. This is clearly shown by the widening gap between the actual values based on scientific evidence and the default values that the Commission has drafted. The core idea of the Renewable Energy Directive is to significantly increase the share of renewable energy in the EU as part of achieving climate targets and reducing greenhouse gas emissions. As a consequence, any policy development has to support this objective whilst setting relevant framework conditions. EUSTAFOR also wishes to emphasize that forest biomass for energy production is in many areas in Europe the only viable business model for low-quality wood. While EUSTAFOR supports the principle of using wood for the most value-added purpose, the biorefineries needed for innovative products are currently few and far between.
Additionally, from a geopolitical perspective, it would be unwise to deter investments in biomass in an era where Europe tries to become strategically independent from foreign energy sources.

To make a serious transformation into a biobased economy happen, predictability of any market-oriented decision must be guaranteed. Operators and investors in long-term investments need legal certainty they can rely on. EUSTAFOR calls for careful consideration whether the proposed changes contribute positively to said legislative stability.

For further information on our position we refer to our attached document.