CEPI position on the Commission proposal for a regulation on the inclusion of GHG emissions and removals from LULUCF into the 2030 climate and energy framework
The main goal for the European pulp and paper industry in the debate on climate change and forestry is to work on a policy framework enabling the long term sustainable management of European forests. This is in line with the conclusions of chapter 9 of the 4th Assessment Report of the International Panel on Climate Change (IPCC): “In the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks, while producing an annual sustained yield of timber, fibre or energy from the forest, will generate the largest sustained mitigation benefit.”
The main concern of the European pulp and paper industry is that proposals for the inclusion of GHG emissions and removals from LULUCF focus on the 2030 horizon and forest sequestration. Meanwhile the potential of the other aspects of sustainable forest management such as the absorption of carbon by more dynamic forest management and storage and substitution of wood products replacing fossil based ones would not be sufficiently recognised and harvesting levels would be reduced.
The European pulp and paper industry is a key contributor to the bioeconomy. It uses wood from sustainably managed forests to produce renewable and recyclable products which substitute more carbon intentive products.. In addition, the European pulp and paper industry produces bioenergy with highly efficient combined heat and power generation. Further increasing the efficiency of the wood use, the industry is developing new products based on wood to grow the bioeconomy and even more substitute fossil based materials. The mitigation potential could be further improved by further supporting the growth of forests, dynamic forestry and the mobilisation of wood, the use of wood-based products, high value added products, the cascading use principle and strengthening innovation in new bio-based products.
Accurately accounting the emissions/removals from the sector is crucial to demonstrate that European forests and the use of its products have a positive contribution to climate change, as forests absorb carbon from the atmosphere and sequester it. Harvested wood products store carbon and substitute fossil based products. Along the chain, wood, harvesting residues and industrial residues are also used to produce bioenergy substituting fossil fuels. (Replacing fossil fuels by bioenergy is an interim target on the way to bio-based value chains creating high value added from products, materials and fuels.)
In the last decades, forests in Europe have been growing both in surface and in growing stock. Looking ahead, Chapter 9 of the 4th Assessment Report of the IPCC states: “In the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks, while producing an annual sustained yield of timber, fibre or energy from the forest, will generate the largest sustained mitgigation benefit. Most mitigation activities require up-front investment with benefits and co-benefits typically accruing for many years to decades. The combined effects of reduced deforestation and degradation, afforestation, forest management, agro-forestry and bioenergy have the potential to increase from the present to 2030 and beyond”. The combined climate change mitigation effect should be maximised. Therefore disproportionate measures on one of these elements should be avoided.
In this context CEPI and its members welcome the recognition of forests and forest products in the EU’s new climate and energy policy framework 2020-2030 and the inclusion of the land use, land use change and forestry sector in the framework.
Even though the proposal is on a 10 year period, it should incentivise the long term carbon benefits of forests and the bio-economy. The inclusion should not lead to an optimisation for the 2020 to 2030 period. In the long term, Europe will need more wood products.
The regulation should provide a framework incentivising Member States to promote a forest management, which increases the capacity of its forests to take carbon out of the atmosphere and at the same time store it in products that substitute fossil products.
The Commission proposal includes several positive principles:
Emissions from the land use sector are reported when harvesting takes place. Carbon emissions should be accounted once. Emissions from the combustion of biomass should therefore accounted as zero to avoid double counting. This also ensures the climate effect of the wood use is allocated to the country in which the trees are harvested.
Harvested Wood Products (HWP) are recognised as carbon pools contributing to the mitigation efforts. We believe this is a very important element of the framework, as HWP provide a mitigation potential well below the 2020-2030 period.
Flexibility between LULUCF and the effort sharing sector is limited to afforestation. This gives Member States with potential for afforestation the possibility to use this abandoned land for afforestation. The potential for afforestation is varying strongly between Member States. However, we believe it is not necessary to limit this flexibility to 280 million tons of CO2. There should not be flexibility between LULUCF and effort sharing sector for forest management.
We believe that the Commission should continue work towards international progress in carbon accounting and encourage other world regions to account for their emissions from LULUCF, particularly countries from which the EU is sourcing wood for bioenergy and products. A credible and though workable scheme in Europe could facilitate the uptaking of similar initiatives in other world regions. Such bottom-up approach has proven successful in the Paris agreement.
Finally we welcome the fact that the proposal is directed to the Member States rather than smaller entities. This ensures the contribution from forestry is regarded upon in landscape approaches and with long time frames.
The Commission proposal contains provisions to be improved:
The framework should be comprehensive and as flexible as possible to further allow Member States to develop policies based on their national conditions.
Forest management reference levels should be set on the basis of long timeframes in order to better reflect trends and responses to climate change policies and measures already in force. These timeframes should enable reference levels to emphasise the impact of most recent policy instruments affecting forest resources, forest management and use of forest products in the country.
The setting of projections based on reference levels has to be credible and transparent and should be based on subsidiarity in forest related issues. The European Commission’s role should be focused on ensuring harmonised country established reference levels and on ensuring credibility and transparency rather than a centralised recalculation on those national elements.
The criteria for the establishment of forest reference levels should be reviewed and better focused on carbon relevant criteria. Biodiversity conservation is already addressed in specific EU and national legislation and this should be reflected in policy.
The option chosen by the Commission is based on the no-debit rule. CEPI believes the no-debit rule is crucial in the LULUCF proposal to demonstrate that the forest sector acts as a sink. However, we believe that Member States demonstrating they harvest less than the net annual increment should not be sanctioned.
SÃO PAULO – The theme of the 2017 United Nations International Day of Forests is Forests and Energy. The International Council of Forest and Paper Associations (ICFPA) of which CEPI is a member is proud to represent the global forest products industry, which plays an important role in contributing to the production of renewable energy. While manufacturing its products from wood sourced from sustainably managed forests, the industry reduces dependence on fossil fuels. It uses by wood manufacturing residuals, byproducts and forest residues – collectively known as biomass – to produce efficiently much of the energy required for its operations and provides heat to local communities as well as to electrify the grid.
According to the international carbon accounting principle, when combusted for energy, biomass does not contribute to global climate change as growing trees sequester carbon from the atmosphere via photosynthesis. The ICFPA reiterates the carbon neutrality of biomass in a policy statement here
“The sustainable management of forestry including the efficient use of biomass for energy is key to achieving global climate change commitments and are core principles in making the low-carbon bioeconomy a reality in Europe.” says Sylvain Lhôte, Director General at CEPI
According to the United Nations Food and Agriculture Organization, wood provides the world with roughly 40 percent of current global renewable energy supply – more than solar, hydroelectric or wind power. Sustainably-managed forests have a key role in meeting several United Nations Sustainable Development Goals and providing solutions for a growing green economy.
To increase the role of forests in providing renewable energy and to reduce the use of fossil fuels, the forest-based industry invests in technological innovation and sustainably-managed forests to improve yields and practices. In the past ten years, the energy share of biomass and other renewable fuels has increased ten percentage points from 53 to 63 percent.
The ICFPA represents more than 30 national and regional forest and paper associations around the world, including CEPI
For more information about the sustainability of the global forest and paper industry, visit icfpa.org.
European forest owners, managers and forest-based industries released a joint statement today, outlining key elements to be included in the review of the FOREST EUROPE process to ensure Sustainable Forest Management (SFM), at the first meeting of the working group on the future direction of the FOREST EUROPE in Bratislava.
European forest owners, managers and forest-based industries released a joint statement today outlining key elements to be included in the review of the FOREST EUROPE process to ensure Sustainable Forest Management (SFM) at the first meeting of the working group on the future direction of the FOREST EUROPE in Bratislava.
The signatories of the joint statement acknowledge the importance of the FOREST EUROPE process for the development and implementation of SFM in European forests. In the 1990s, European Forest Ministers gathered to share their concerns about the health of European forests and to seek solutions to improve it. Since then, FOREST EUROPE has helped to ensure that we have well functioning forest monitoring systems, research programmes, gene banks and advanced forest fire prevention systems. It also contributed to the global forest agenda agreed at the UNCED Rio Summit in 1992. It enables SFM to be economically viable at the same time as protecting forest biodiversity, soils, water sources, the use of forest biomass for bioenergy and other purposes. Last but not least, it succeeded in opening a completely new chapter on discussing a legally binding framework for Europe’s forests.
However, it is important to review the FOREST EUROPE process to ensure that today’s challenges in the forest and forest-based sector, which are more complex and demanding than ever, can be met. European forest owners, managers and industries therefore welcome the set-up of the working group on the future direction of FOREST EUROPE. The signatories of the joint statement believe that FOREST EUROPE needs to be able to respond to current and emerging challenges and opportunities, such as climate change, bio- and circular economy, sustainable sourcing of bioenergy, as well as green capital and the marketing of ecosystem services. It is crucial to strengthen FOREST EUROPE now to further develop the sustainable management of European forests and their multi-purpose use for the benefit of everyone. The signatories of the joint statement call for FOREST EUROPE to demonstrate leadership in this regard.
One of the biggest merits of FOREST EUROPE, which involves 46 European governments, the European Commission as well as numerous forest sector stakeholders and other international organizations, is that it enables stakeholders to have open and constructive dialogue. European forest owners, managers and industries will play an active part in the review process and contribute to the elaboration of a report by the end of 2017 to ensure that FOREST EUROPE is stronger and more effective in the future.
The joint statement was issued by major public and private forest owners, managers, other land owners and forest-based industries, represented by the Confederation of European Forest Owners (CEPF), European Farmers and European Agri-Cooperatives (COPA and COGECA), European Landowners’ Organization (ELO), European State Forest Association (EUSTAFOR), European Federation of Municipal Forest Owners (FECOF), and Union of Foresters of Southern Europe (USSE), the Confederation of European Paper Industries (CEPI) and the European Confederation of Woodworking Industries (CEI-Bois).
"To build a sustainable, climate-resilient future for all, we must invest in our world's forests.”
– UN Secretary-General Ban Ki-moon
The European forest owners, managers, forest industry and professionals, represented by key stakeholders of the European forest sector: CEPF, Copa-Cogeca, ELO, EUSTAFOR, CEI-Bois, CEPI, FECOF, UEF and USSE, welcome the declaration by the UN General Assembly of the International Day of Forests on 21 March which this year has the theme “Forests and Water”.
Water is a vital element of all natural resources and essential to life, but nearly 80 percent of the world’s population is exposed to high levels of threat to water security. There is a growing imbalance between water supply and demand in the world, and also in Europe we increasingly need to ensure adequate water quality and quantity.
The European forest sector welcomes the opportunity to emphasize the role of forests and water. We consider that EU needs to better communicate the strong link between forests and water. Forests have a close relationship to our water resources and sustainable forest management is of crucial importance for ensuring a multitude of water-related benefits.
As representatives of the European forest sector we would like to highlight some of the important ways in which our forests enable access to this vital resource. Forested watersheds and wetlands supply 75 percent of the world’s accessible fresh water for domestic, agricultural, industrial and ecological needs. Forests influence the amount of available water and regulate surface and groundwater flows while maintaining highest water quality. Forests reduce the effects of floodings, and prevent and reduce dryland salinity and desertification. Forests act as natural water filters, minimizing soil erosion on site and reduce sediment in water bodies.
In the context of this year’s International Day of Forests, we also need to mention the impact that climate change has on water and the role of forests. Climate change is one of the major challenges facing today’s society. The impacts of climate change are an imminent threat to water security, and forests themselves are vulnerable to climate change. An increased frequency of extreme weather events has an impact on both forests and water, and may result in more catastrophic events like landslides, floods and droughts.
However, forests can also help reducing the impacts of such events. Europe’s forest sector is at the forefront of combatting climate change by contributing to both climate change mitigation and adaptation. Active forest management is crucial to enhance forests adaptive capacity, making them more resilient to meet a changing climate and maintaining the vital water-related services provided by forests.
CEPF – Confederation of European Forest Owners
Contact: Meri Siljama email@example.com, www.cepf-eu.org
COPA-COGECA – European Farmers European Agri-Cooperatives
Contact: Oana Neagu firstname.lastname@example.org, www.copa-cogeca.be
CEI-BOIS – Confederation of European Woodworking Industries
Contact: Ward Vervoort email@example.com, www.cei-bois.org
CEPI – Confederation of European Pulp and Paper Industries
Contact: Annie Xystouris firstname.lastname@example.org, www.cepi.org
ELO – European Landowners’ Organization
Contact: Ana Rocha email@example.com, www.europeanlandowners.org
EUSTAFOR – European State Forest Association
Contact: Gerd Thomsen firstname.lastname@example.org, www.eustafor.eu
FECOF – European Federation of Municipal Woodowners
UEF – Union of European Foresters
Contact: Michael Diemer email@example.com, www.european-foresters.org
USSE - Union des sylviculteurs du Sud de l'Europe
Contact: Isala Berria firstname.lastname@example.org, www.usse-eu.org
The sustainable forest management framework has evolved and strengthened over time balancing a market based demand for wood products and bioenergy with the other environmental and climate functions of the forest.
More recently, the EU policy framework to support the use of energy from renewable sources has led to a strong increase of bio-energy use within short timeframes. The increased demand has led to rising imports of wood. To ensure the sustainability of the policy induced increase of bioenergy use and wood imports, the following issues have to be considered:
• Do the needs for wood biomass lead to any of the following critical consequences: resource depletion, land conversion, negative impacts on biodiversity?
• Is the direct burning of wood biomass an efficient use of a raw material that could first be used for higher value purposes?
• How could monitoring, reporting and verification ensure carbon sustainability?
To address the increased use of wood for energy and to design a sustainable biomass policy framework for the post 2020 period, CEPI believes that the following criteria for the production of bioenergy counting towards EU renewable energy targets should be considered while taking into account the use of existing legal and market based instruments at national, EU and global level.
1. Biomass sourcing
Biomass should come from sustainable sources. Biomass is a renewable source of energy if it does not lead to harvesting beyond the sustainable level and preserves the other functions of forests according to the principles of Sustainable Forest Management (SFM).
a. Carbon sustainability:
Forest biomass shall come from countries with credible LULUCF accounting and reporting. If biomass is procured from non-LULUCF accounting countries, credible proof has to be given that there are systems for monitoring, reporting and verification in place ensuring that the harvesting rate in this country is below 100% in the long term and the biomass does not come from land conversion (leading to depletion of carbon stock). Where there is overharvesting at the country level, the energy producer has to give sufficient proof that there is no overharvesting at the relevant regional level of the biomass origin.
Reporting should continue to take place according to the instant oxidation principle. This ensures that the climate effect of the wood use is allocated to the country in which the forest is harvested.
b. Forest management
Forest biomass shall come from legal sources.
In order to ensure that the three main challenges relating to forest management – resource depletion, land conversion and loss of biodiversity – are addressed, the following trend indicators provide sufficient assurance:
1. Growing Stock: The felling rate (harvested volume/net annual increment) must be lower than 1 in the long term (information source: e.g. National Forest Inventories) in order to avoid overharvesting.
2. Gross Deforestation: The area under forest cover must be maintained (except if deforestation is the result of “land sealing” (infrastructue building, urban expansion, etc. which is limited in surface) (information source: e.g. NFI)
3. Biodiversity: No biomass harvesting can take place in protected forests, unless the protection decision allows management and harvesting.
Additional considerations on the proposed approach:
• The measurement of meeting the above indicators must take place within well defined spatial and time dimensions. As far as the spatial dimension is concerned, the country level is relevant. Choosing the appropriate spatial level will allow for robust reporting and monitoring, both in terms of carbon emissions and removals (LULUCF reporting), as well as in terms of forest inventory (fellings areas, etc.)
• A stand level and short-term horizon is not acceptable as it would make compliance with such indicators both impossible and irrelevant. Harvesting lowers the carbon storage in stand level for a certain period, but at the same time at the landscape level, carbon storage continues to be maintained or increased.
• The obligation of proof should be solely with the energy producer.
• Demonstrating compliance should be credible, but not too burdensome to the suppliers and the buyers. Red-tape leading to extra cost would be a disincentive to additional mobilisation of forest resources.
• Similar to the EU Timber Regulation an approach of risk assessment (via national/regional (where relevant) data according to the three indicators outlined) should be investigated. Only if the risk assessment at country level can not give thourough proof, the regional/landscape level should be adressed.
• New means of proof should avoid being a further burden when competing with other industries and products based on fossil and more carbon intensive raw materials as well as with forest industries based outside Europe.
• The tools developed by the forest sector should be used to proof the origin from sustainable sources along the chain of custody.
• In that context, different voluntary instruments and tools addressing forest management should be evaluated and recognised.
2. Biomass conversion
a. Greenhouse Gas Savings criterion:
There should be GHG savings compared to the average European fossil fuel based generation of electricity and heating and cooling.
• The GHG emissions reduction criteria should be based on the GHG emissions calculations methodology recommended by the Commission in 2010 (COM(2010)11) and confirmed in 2014 (SWD(2014)259).
• There should be coherence with the biofuels GHG emissions threshold (60%) as wood can be used to produce power, heat or biofuels.
• The methodology and default values should be established for at least the same period as the post-2020 RES target.
b. Conversion efficiency:
Heat and electricity based on solid and gaseous biomass should be produced at an overall efficiency of at least 70% (lower for small installations (e.g. < 1 MW) or where CHP cannot be applied). Member States should not support but further even avoid the use of biomass in new conversions of coal plants with the current low efficiencies. Supporting co-firing of biomass in coal plants at low efficiencies is an environmentally harmful subsidy.
Meeting the conversion efficiency and GHG savings criteria should be verified by schemes similar to biofuels sustainability criteria. The obligation of verification should be with the energy producer. Mutual recognition of schemes should be ensured to limit red tape.
A background paper accompanying the position can be downloaded here.