Posted on March, 06 2023

Why does this matter?

The RED revision, as part of the Fit for 55 package and RePowerEU, is a key moment for the EU to set out its road map towards a renewable future. The consequences of climate change are becoming more and more visible and the window of opportunity to keep temperature rise to 1.5°C is rapidly closing. On top of that, the war in Ukraine has put us into a fossil-fueled energy crisis and it is clear that we urgently have to reduce our dependence on unreliable fossil gas. 

The European Union is moving fast to offer a solution to these climate and energy crises, but WWF argues EU co-legislators have to be wary of the implications of some of these proposals, including on bioenergy and hydropower and the exemption from the carrying out of an Environmental Impact Assessment (EIA).

“A rapid and massive expansion of wind and solar power is the key to getting out of this fossil-fueled energy crisis, but this should not be done at the expense of nature. It should be achieved by better spatial planning and more administrative capacity in permitting authorities, not scrapping rules on environmental protection or public engagement. Environmental impact assessments are essential to guarantee that the energy transition tackles both climate change and the biodiversity crisis,” said Arnaud Van Dooren, Policy Officer, Climate & Energy at WWF Europe.

What will WWF be looking for?

On the Renewable Energy Target
WWF welcomes a higher renewable energy target and supports the European Commission and European Parliament’s proposal to reach at least 45% renewables in the energy mix by 2030. Even though science and a recent analysis suggest we could and should be aiming for at least 50% renewables by 2030, this can be seen as a big step from the previous 32% target, and also the 40% target in the original Fit for 55 proposals.

That being said, a potential agreement on a higher target (e.g, 45%) should not be achieved by letting “low carbon energy” such as nuclear be taken into account when setting renewable energy targets. This would endanger the development of renewables, by diverting investments from cheaper, faster and safer alternatives, and have potentially serious lock-in effects.

On Bioenergy
On bioenergy, the question of what types of biomass will be incentivised by the RED is still under discussion. WWF supports the Parliament’s proposal for a limit of the amount of unprocessed wood directly taken from the forest such as tree trunks and branches (primary woody biomass) that can be counted as renewable energy. This will avoid further expansion in the burning of feedstocks that can increase emissions compared to fossil fuels for decades to centuries, based on the findings of the Joint Research Center (JRC) and a letter from 800 eminent scientists. 
 
During these final negotiations, WWF will be looking to co-legislators to agree to:

• Cap the amount of primary woody biomass that can be counted towards the 2030 renewable energy targets
• Phase out subsidies for the use of primary woody biomass
• End all incentives in the RED for bioenergy produced from dedicated crops, including palm and soy

On ‘go-to’ areas and the nature-friendly expansion of renewables
WWF supports the creation of ‘go-to’ areas for the development of renewables. However, projects in these areas should still be subject to an EIA, and there should be no ‘go-to’ areas for hydropower or bioenergy projects, which can have serious climate and/or biodiversity impacts. 

WWF is supporting the creation of a new Article 15d on the need to include public participation in the process of establishing these areas. We want this article to include the importance of bringing local communities and citizens on board from the start of renewable projects, as mentioned in our position paper.

On offshore wind and solar energy, WWF advocates for priority areas to align with the requirements of the Maritime Spatial Planning Directive, which recommends the Member States use an ecosystem-based approach to maritime spatial planning (MSP) when designating renewable energy sites. WWF has called on the European Commission and Council of the EU to uphold the European Parliament’s amendments to Article 15c during the EU Renewable Energy Directive trilogue negotiations, which:

• recognise the importance of building on already existing planning tools such as national Maritime Spatial Plans when allocating space at sea for renewable energy projects;
• exclude marine protected areas and marine mammal migratory corridors - which are essential for the survival of marine life from the list of sites to be prioritised for offshore renewable energy.

On Hydropower
WWF argues that hydropower is not the future of renewable energy, as 130+ organisations emphasised in an open letter, published a few weeks ago. Hydropower potential has been so exploited already in Europe that new hydropower would only make a very small contribution to the energy transition, while causing immense damage to our waterways. According to WWF’s Living Planet Report 2022, monitored freshwater migratory fish populations have declined by 93% in Europe, with dams as a major cause, making our continent the most affected in the whole world. Also, the impacts of climate change on water availability make hydropower production more and more unreliable.

Therefore WWF is asking EU co-legislators to:

• In RED III - Retain article 29b. Sustainability criteria for hydropower, proposed by the EP, as it recognises that hydropower has direct impacts on freshwater ecosystems which must be mitigated. 
• In RED IV - Prevent Member States from establishing go-to areas for hydropower.

Contact
Florian Cassier
Climate Communications Officer
WWF European Policy Office
fcassier@wwf.eu
+32 479 33 92 11