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they will apply the most recent IPCC 2006 guidelines, based on the above-mentioned principle, in implementation of their contributions. This is a promising development towards embracing common methodologies within international climate policies. The Paris Agreement also requires all parties to improve their LULUCF inventories and reporting methods. The EU is already acquainted with LULUCF accounting methods and an important proposal from the Commission on how to integrate this sector into the EU overall GHG emissions reduction objective is expected this Summer. On the ground, bioenergy production is not isolated from other wood uses: we often see more synergies than competition. For example, in Finland, residues used in heating installations come mostly from the value chains of the forest industry to generate timber and wood fi bre. Sustainable forest management consists of a wide set of actions that range


from sophisticated harvesting to regenerating wood, maintaining an adequate carbon sink and to ensuring biodiversity. In Finland, for instance, the bioenergy market enables forest operators to proceed with thinning operations that will eventually lead to stronger forest growth, carbon stock increase and to high-value timber. The future EU sustainable bioenergy policy should take into account the fact that a single biomass type can be used to produce heat, electricity and biofuels. For instance, woodchips can be burned to produce heat and/ or electricity, but also lignocellulosic biofuels depending on the real market conditions, which keep on evolving in the future. It therefore makes sense to address the sustainability of the raw material and to trust the ability of the market to fi nd the best value, rather than try to develop theoretic concepts around the different end-uses. The future EU policy should also ensure that biomass contributes


to GHG savings by setting a minimum GHG emissions savings threshold based on calculation methodologies, such as the one already endorsed by the Commission.


I truly believe that a robust bioenergy policy is achievable by building on the existing policy framework. Several key EU legislations are in place or in the pipeline – on renewable energy, biodiversity, wood trade and land use change. If properly implemented and reinforced by national legislation and voluntary systems, this legislation could provide the foundations of a sustainable EU assurance system. Such a system should take into account the administrative costs and burdens that companies – in particular SMEs - will eventually face. SMEs could be hindered by an unrealistic approach, acting de facto against locally-available sustainable bioenergy and therefore against climate targets and employment rates within European rural


AEBIOM


areas. This is why The Bioenergy Association of Finland, together with AEBIOM and its networks, is asking the European Commission to adopt a reasonable, credible threshold of 20 MWth, coherent with ETS legislation, to apply its future sustainable bioenergy policy. This is also why the European bioenergy sector supports the risk-based approach (RBA) at macro level (regional or national) to evaluate whether forest biomass is originating from forests where biodiversity and ecosystems are thoroughly protected and the carbon stock is maintained. Finally, what companies investing in European sustainable bioenergy solutions today require can be summed up in one word: confi dence. The European Union has the capacity to send a strong policy signal and we should use it! What is not needed for currently the most important source of renewable energy is a short- sighted policy with built-in revision requirements.


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