Accounting for the greenhouse gas emissions from forest-based bioenergy in EU legislation: a critical analysis of the presumption of carbon neutrality in the Renewable Energy Directive and the Land-Use, Land-Use Change and Forestry Regulation with Finland as example of implementation at the national level

Abstract

As largest source of renewable energy, forest-based bioenergy is an important source of energy for the EU. In the Renewable Energy Directive, the EU instrument that promotes the use of renewable energy, forest-based bioenergy is considered to be a carbon neutral source of renewable energy. This presumption is connected to the condition that the emissions from the harvesting of trees as a result of the production of forest-based bioenergy are accounted for under the Land-Use, Land-Use Change and Forestry Regulation. However, this system of carbon neutrality shows inconsistencies with science and gaps in the associated accounting system. In Finland forest-based bioenergy plays an important role in the energy production and consumption. The question rises if Finland has the opportunity to fill in the gaps from the EU framework when implementing the EU framework in its national legislation and to ensure that the use of forest-based bioenergy can be aligned with the emission reduction target of the country.