REDII sustainability criteria

The Finnish Association for Nature Conservation thinks this guidance is not enough to ensure the sustainability of forest biomass used in energy production. We need a revision of the REDII in order to create a system that favors renewable energy solutions that are actually climate neutral and not based on burning. Burning of wood is not climate neutral and should not be treated as such. We also need a criteria that makes a clear difference between the use of secondary forest biomasses and primary forest biomasses in energy production.

We are calling for stricter sustainability criteria for forest biomasses. We need to stop burning tree trunks (over 10 cm diameter), stumps, deadwood, and biomass from protected areas. The sustainability criteria should be applied to all installations, not just those over 20 MW and 2MW.

The guidance relies on national laws but the existing national laws are not enough to ensure the sustainability of forest biomasses from climate or biodiversity perspectives.

We hope that this guidance will be a start for developing and putting to practice actually functioning sustainability criteria for forest biomasses. It is good that the guidelines mention (article 3, 1 b ii and article 4,1 b iv) that there should be no biodiversity degradation or degradation of primary, natural or semi-natural forests. Soil quality protection (as in (article 3, 1 b iv and article 4, 1 b iv) should be concerned especially in the peatland forestry as it causes CO₂ emissions each year from the long term carbon storage of forest soil. It is good that the article 4 1 b iv mentions that clearcuts should be minimized and that there should be no collection of roots and stumps. These are all valid points but it is still doubtful that the guidance system presented will ensure that all the points mentioned above actually happen. In order to make sure that the guidance criteria is followed through there should be checks on the ground by auditioners or MS.

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