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INFORSE-Europe Comments for EU Biomass and Biofuels Strategies
December 31, 2006

There is an urgent need for increased actions for biomass to reach energy and climate targets, thus it is time to introduce sustainability criteria in the use of biomass, in particular biofuels. This is why INFORSE-Europe welcomed the EU Biomass Action Plan and the following EU Biofuels Action Plan, as well as their ongoing implementation. INFORSE-Europe also proposes Criteria for Sustainable Use of Biomass.

Biomass and Other Renewables for Heating
We strongly urge the EU to continue work on a directive for renewable energy for heating and cooling as part of a strategy to boost renewable energy use. As part of the directive we propose:

National targets for 2010 coherent with national climate targets and the overall EU-15 target of 12% renewable energy in primary energy supply.
National targets for 2020 adding up to and EU-25 target of 25% of demand for heating and cooling. National targets for 2015 should be set in line with the 2020 targets.
Introduce a progressive labelling system for energy efficiency and air pollution of biomass heating equipment.
Set progressive standards for energy efficiency and air pollution for biomass heating equipment on the market. The standards should be strengthened every 5 years. Countries with high use of biomass should be allowed to introduce higher standards to avoid local air pollution problems in areas with large biomass combustion.
Regular inspection of air pollution as part of mandatory safety checks of boilers and ovens with visual inspection of chimney.
Consumer information systems in all countries, informing about clean and efficient use of biomass for heating.
Request of solar heating when it is cost-effective in new buildings and when buildings are renovated with replacement of roof and/or heating system.
Request to designers about considering passive heating and cooling in building designs.
Request of renewable heat preference over fossil fuel based heating, including gas distributed in networks and district heating primarily fuelled with fossil fuels.
Request of renewable-based heat and gas to enjoy the same right to feed into gas and heat networks that renewable electricity do.
Support schemes for renewable heat should be limited to heat production where inputs of fossil energy and electricity are less than 20% of the heat produced combined, similar to the fossil energy used to provide fossil energy to end-users.
Support schemes for biomass should be limited to biomass that is produced in sustainable ways, following criteria for the sustainable use of it.

In addition to the directive, INFORSE-Europe has suggested a set of criteria to support renewable energy heating:

1. Support for R&D in biomass for heating to develop cleaner, more flexible, more user friendly and more efficient equipment.
2. Support for R&D in renewable cooling to make it ready for the market.
3. Support for R&D in renewable CHP, in particular, small-scale.
4. Support for demonstration of new, efficient and clean solutions for renewable heating and cooling.
5. Campaign for new technology in renewable heating and cooling.
6. Priority for renewable heating in structural funds.
7. Priority of renewable heat in national and EU lending schemes.
8. Establishment of funds for loans to renewable heating, based on EiB loans and structures with minimal added interests.
9. Introduction of state guarantees for establishment, conversion and expansion of district heating and district cooling systems based on renewable energy.
10. All tax preferences for fossil fuels over renewable energy and district heating must be ended, such as lower VAT on fossil fuels.

Biomass for Electricity
We also welcome the emphasis on increased biomass use for electricity as part of meeting the target of 22% renewable electricity by 2010. Crucial to this is that the countries and the EU Commission should do an increased effort to achieve the targets for renewable electricity. In addition to provisions in the RES-E directive is proposed:

The countries should introduce support mechanisms that are sufficient to meet targets.
The Commission should work for the use of EU-wide support mechanisms including agricultural support and availability of structural funds for biomass production.
A special priority should be on efficient and biomass-based cogeneration.
National targets for 2015 and 2020 should be set in line with increase of renewable energy supply to reach 25% of primary energy supply in 2020 for the EU-25.
R&D should emphasize the development of smaller units for efficient biomass-based CHP as well as the increased conversion efficiency from biomass to electricity.

Biomass and Other Renewable Energy for Transport
INFORSE-Europe welcomes the emphasis on biofuels including the special concern by the Commission on sustainable production of biofuels. We believe that the future of biofuels in transport is closely linked with the environmental sustainability of the production and that support systems should encourage the development of sustainable biofuels. Therefore we promote Criteria for Sustainable use of Biomass. We further recommend:

That biofuels which do not follow environmental criteria, such as those proposed by INFORSE-Europe, are not encouraged by support systems and do not count to fulfil renewable energy targets.
That tax reductions are graduated according to climate impact, giving maximal support for biofuels with climate impacts of less than 20% of the CO2 that it replaces in fossil fuel use.
That imported biofuels should follow the same criteria that are used for domestic production, and that energy for the long-distance transport is included in the evaluation of support levels.
In case of uncertainty with sustainability of imported biofuels, imports should be stopped. It is specifically proposed to stop import of vegetable oils for biodiesel because of the risk of increasing deforestation and clearing of rainforest to give way for oil plantations.

Use of biofuels should not be used as an instrument to meet the climate target of 120g CO2/km for personal cars. It is basically an efficiency target and it should be achieved via efficiency measures including the existing voluntary agreements, and if it is insufficient, by mandatory measures, supplemented by tax incentives for the most efficient vehicles.

A broad approach should be taken to renewable energy in transport, combining liquid biofuels with biogas for transport and electrically driven vehicles with the electricity produced from renewable energy.

INFORSE-Europe supports the increased research and development activities for production of liquid biofuels from solid biomass and wet organic waste.

INFORSE-Europe also supports the emphasis on assisting developing countries producing biofuels for transport. This production should also be sustainable, and emphasis should be put on making an increasing number of self-sufficient countries in transport energy supply.

Biomass Supply
In several countries there is still need for market development. It is proposed that the countries make biomass action plans to support the market development to ensure availability of a minimum range of biomass products that are produced in sustainable ways according the agreed criteria. This should include, e.g.:
-Wood pellets and wood chips, except in countries without heat demand.
-Vegetable oil, biodiesel, and bio-ethanol.

Regarding agricultural policies, it is proposed that support for biomass crops on farmland should be similar to food crops support. The support should be on the condition that sustainability criteria are fulfilled. The support for energy crops should in general not be graduated according to the kind of crops grown, but according to the environmental impacts including on energy inputs in the production.

Regarding structural funds, it is proposed that priority is given for funding of renewable energy and energy efficiency infrastructure including funding for accompanying infrastructure such as for district heating systems supplied with renewable energy.

There is a large potential to use certain types of waste for energy; but there is certainly also large risk if waste is not treated properly. To increase sustainable use of waste fractions for energy is proposed:

-Use of clean fractions of wood and agricultural waste for energy.
-Increased emphasis on sorting wood residues from untreated wood into separate fractions.
-Increased emphasis on sorting of wet organic waste in fractions that are not contaminated with heavy metals or POPs, for use in biogas plants.

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