COSE warns that removing subsidies for primary biomass will increase the risk of wildfires in Spain.
The Confederation of Forestry Organisations of Spain, Cost of doing business, held its annual assembly on the 6th and 7th of June in Castellar de la Frontera (Cádiz), where representatives from the different autonomous communities met to discuss the most strategic forestry issues for the sector. One of the main issues addressed was to warn the relevant administrations and their political leaders of the serious risks that could arise from the elimination of European aid for primary biomass, namely the residues resulting from forest management and maintenance work. The national organisation represents more than three and a half million private woodland owners in the country, which amounts to a forested area of around 20.1 million hectares (73% of the national total), supporting most of the forestry activity and the generation of strategic resources for society and the sector's industry.
The European Commission's Directorate-General for the Environment has proposed a major review of the sustainability criteria for bioenergy. One of the measures, which is set to be approved on 15 July, will be to restrict the use of primary forest biomass – that is, forestry residues – for renewable energy targets. According to the Directorate-General, primary biomass would not count towards the renewable energy target, nor would it receive any financial support.
Given that in Spain bioenergy from biomass (wood) is largely based on the residues of forest management practices (for example, clearings), the concern of foresters is evident, since if biomass is excluded from the renewable energy target, incentives for active forest management would be reduced. And without active forest management, the risk of large wildfires would increase alarmingly.
Furthermore, it would hamper the bioeconomy of forest enclaves by reducing a source of income from this resource, and would worsen energy dependency and poverty, as both primary and secondary biomass are an important climate solution due to their role in replacing fossil fuels. In addition, the increase in forest biomass in the woods would pose a risk in terms of natural disturbances (pests and diseases) and hinder regeneration. And according to the latest research, a less-managed forest is one that absorbs less CO2.2 and with a greater risk of wildfires.
To this is added the complex regulation and bureaucracy that would be incurred by incorporating more specific sustainability criteria, which would further hinder the development of appropriate forest management, with the risk of abandoning the woodlands and their activity. Finally, this proposal conflicts with the purpose of RePowerEU, which aims to increase the renewable energy target to 45 per cent.
Therefore, COSE rejects the idea of establishing separate categories for primary and secondary biomass, and calls for amendments to allow primary biomass to count towards the renewable energy target. It is important to recognise that the market already ensures that high-quality wood is used for high-value-added products, which means that the wood energy sector does not use high-value roundwood as a raw material, one of Europe's concerns. It should also be borne in mind that the biomass generated in many Mediterranean forests has no other destination than bioenergy.
A Forestry Taxation
Another of the issues approved at the annual assembly was the request for a series of fiscal proposals that could reverse the situation of progressive abandonment of forest activity. These proposals take into account the realities of silvicultural activities such as long production cycles and long payback periods for investments, the lack of economic profitability, health threats and a high risk of forest fire that increases with ever hotter summers, droughts or gales, and with risks stemming from the very nature of such a long-term market. According to a report by the Bank of Spain, It is essential to enhance and improve environmental taxation so that the economy can advance efficiently and at lower cost in the process of ecological transition.
Accordingly, the following proposals were presented:
- Compatibility (under certain circumstances) between the Direct Assessment Regime and the Objective Assessment Regime.
- Partial exemption of income from the sale of timber from species with a rotation period exceeding 30 years.
- Deduction in the Personal Income Tax and the Corporation Tax for expenses and investments made by foresters active in the conservation, maintenance, improvement, protection and access of the forest.
Active silviculture benefits society as a whole: it is an insurance policy for job and wealth generation in rural areas, a brake on fires and pests, and a means of conserving and enhancing the environmental and social functions that forests perform, which are essential for sustaining life on the planet and which, for the time being, remain unrewarded to their owners.
Finally, it was proposed to work jointly to establish financial mechanisms that allow for an increase in CO2 capture by carbon sinks and that have an impact on the owner's management, thereby complying with Article 6 of Law 7/2021 of 20 May on Climate Change and Energy Transition.

