Ref. Ares(2022)5807098 - 18/08/2022
SUSTAINABLE BIOMASS:
CLARIFYING THE “WHOLE TREES” CONCEPT
A number of strategic documents recently published by the European Commission have stigmatised
the practice of using “whole trees” for bioenergy, calling instead for a “transformative approach” aimed
at minimising their use. Organisations representing the bioenergy value chain and the supply of biomass
argue that such an arbitrary physical criterion will not help to ensure the sustainability of the biomass
feedstock but, on the contrary, risks disrupting supply chains, with adverse effects on the efficient use
of available wood resources and, ultimately, on all forest benefits: economic, social and environmental.
The term “whole trees” was first used by the European Commission in the context of the
Biodiversity
Strategy for 2030, and more recently in the
2030 Climate Target Plan Communication alongside several
public consultations. The term is non-technical and largely used emotively.
The archetype of a forest product supply chain is constituted of complex flows of materials through a
myriad of players. High exchange rates between waste products and raw materials have become highly
efficient over time, with market-based systems optimising the allocation of these resources. Markets
have been developed to distribute the full quality-spectrum of wood and wood fibres which, in turn,
stimulates productive and sustainable forest management. Not only do these specialized systems
provide forest-based employment and income for rural areas, they also support a large sector of the
European bioeconomy. The role of forests extends beyond this, however, providing communities with
numerous services, including the promotion of biodiversity and climate change mitigation.
Sustainable forest management is embedded in individual Member States’ national forest legislation.
At EU level, the RED II sustainability criteria for forest biomass ensure the sustainability of this raw
material. Market mechanisms and supply chains follow due diligence and use this resource in the most
efficient way possible.
What is a “whole tree” and why should this definition not become a driving principle
in defining sustainable biomass feedstock?
While the bioenergy industry largely utilises residues and side streams, low-value timber assortments
resulting, among others, from thinning, maintenance and sanitary cuttings can also be utilised, while
continuing to ensure that the sustainability of the value chain is fully respected.
The term “whole trees” cannot be used to define the quality of sawlogs and timber used for added
value purposes. Furthermore, the idea that, in order to guarantee its sustainability, bioenergy should
be prevented from using certain categories of feedstock is based on a misconception.
Joint Paper |
Sustainable Biomass: Clarifying the “Whole Trees” Concept
1. TREE DIAMETER IS NOT A PRESCRIPTION FOR ITS END USE
A sawlog (i.e. a log suitable for being processed in a sawmill and sawed into lumber) is not chosen solely
based on its size and diameter but also on its quality, determined by the absence of faults. The term
“whole tree” can describe a log with a large diameter and of good quality, but it can also describe logs
with a too small diameter or a low-grade tree of poor quality. Pest-damaged wood, for example, does
not usually meet the necessary mechanical characteristics for use in the construction sector or the
required humidity to be processed as fibre. Rather, it needs to be removed from the forest for sanitary
reasons and to limit infestations. Endowing an economic purpose to this damaged wood supports this
process.
2. ENHANCING ECONOMIC VIABILITY WHILE INCREASING FOREST RESILIENCE
Early thinnings are part of a long-term investment to produce high-quality timber. Contrary to
decreasing forest stock, these operations support the higher carbon uptake and quality of the stand as
a whole. In addition, in areas which are prone to forest fires, these early thinnings are among the key
preventive actions aimed at reducing the risk of disaster and increasing forest resilience.
It therefore follows that markets which use lower grade products, such as those which result from
thinnings, allow forest owners to offset the cost of these necessary management operations. This
aspect is especially important in order to support the sustainable forest management of both small-
scale forest owners as well as large-scale forest management organisations.
Both the Circular Economy Action Plan and the Renovation Wave count on embedding carbon in the
construction sector and using renewable materials such as wood. Forest management operations which
enhance the production of high-quality timber must, therefore, be supported in order to accomplish
Europe’s decarbonisation goals.
3. MARKET DYNAMICS RESULT IN THE MOST EFFICIENT USE OF WOOD RESOURCES
Following decades of development, markets have become reliable and efficient mechanisms for
allocating wood resources. They ensure that high-quality logs are reserved for those items which
demand the most longevity - such as timber for construction and furniture. Conversely, the lowest
quality woody biomass can sometimes only be used for bioenergy. This well-established market system
should not be tampered with by ill-advised policymaking.
Introducing diameter-related restrictions as additional sustainability criteria for bioenergy could
impede the flow of raw materials to the marketplace, making it impossible to sell certain large low-
quality logs due to administrative barriers. Similarly, prohibiting the use of “whole trees” could have a
perverse effect on forestry practices and result in negative implications for forest productivity in
general. Furthermore, reducing income opportunities for forest owners and managers would
subsequently be reflected in increased prices for downstream producers and consumers, not to
mention those individuals that rely heavily on biomass for energy.
Joint Paper |
Sustainable Biomass: Clarifying the “Whole Trees” Concept
Legislation minimising the use of “whole trees” would ultimately increase the burden on operators and
trigger a number of unintended and undesirable results. European and national authorities should focus
on the implementation and enforcement of the sustainability criteria as defined in the Renewable
Energy Directive recast. The potential revision of these criteria should be based on a substantial
consultation process that takes direct stock from practices in the field post-implementation (starting in
July 2021).
Bioenergy Europe
is the voice of European bioenergy sector. The association aims at developing a
sustainable bioenergy market based on fair business conditions. Founded in 1990, Bioenergy Europe is
a non-profit, Brussels-based organisation bringing together more than 160 members from across
Europe.
CEPF
The Confederation of European Forest Owners (CEPF) is the umbrella association of private forest
owner organisations in Europe. At EU level, CEPF promotes the values of sustainable forest
management, private property ownership and forest sectors economic viability.
COPA-COGECA
are the united voice of farmers and agri-cooperatives in the EU. Together, they ensure
that EU agriculture is sustainable, innovative and competitive, guaranteeing food security to half a
billion people throughout Europe. Copa represents over 22 million farmers and their families whilst
Cogeca represents the interests of 22,000 agricultural cooperatives. They are one of the biggest and
most active lobbying organisations in Brussels.
EOS
European Organisation of the Sawmill Industry, is a Brussels-based non-profit association
representing the interests of the European sawmilling sector on European and International level.
Through its member federations and associated members, EOS represents some 35,000 sawmills in 12
countries across Europe. Together they represent around 80% of the total European sawn wood
output in a sector that has a turnover of around 35 billion EUR and employs about 250,000 people in
the EU.
EUSTAFOR,
the European State Forest Association, represents the voice of European state forest
management organizations who have sustainable forest management and the production of wood as
major concerns.
Joint Paper |
Sustainable Biomass: Clarifying the “Whole Trees” Concept
