Opinion of the European Economic and Social Committee on the Communication from the Commission on the Biomass Action Plan (COM(2005) 628 final)
Date: 2006-05-17
Institutions: European Economic and Social Committee
Subjects: action programme, bioenergy, biomass, energy production, environmental protection

18.8.2006

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Official Journal of the European Union

C 195/69

Opinion of the European Economic and Social Committee on the Communication from the
Commission on the Biomass Action Plan

(COM(2005) 628 final)

(2006/C 195/19)

On 23 January 2006 the Commission decided to consult the European Economic and Social Committee, in
accordance with Article 262 of the Treaty establishing the European Community and the protocol of coop-
eration between the European Commission and the European Economic and Social Committee of 7
November 2005, on the Communication from the Commission on the Biomass action plan

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
preparing the Committee's work on the subject, adopted its opinion on 2 May 2006. The rapporteur was
Mr Voss.

At its 427th plenary session, held on 17 and 18 May 2006 (meeting of 17 May), the European Economic
and Social Committee adopted the following opinion with 85 votes in favour and five abstentions.

1. Conclusions and recommendations

The EESC welcomes the Commission's Biomass Action
in its view, makes a key contribution towards

1.1
Plan, which,
achieving sustainable development in Europe.

biofuels can,
in principle, make a substantial contribution
towards reducing Europe's dependence on fossil-based energy
sources. In this context, in particular, it is also becoming clear
that, even if an ambitious substitution policy is pursued, the
development of more effective transport systems and a substan-
tial improvement in energy efficiency will continue to be of
decisive importance.

1.2
The analysis of the current expansion of the use of
biomass and the potential of this material provides an initial
overview of the scope for using biomass and the existing obsta-
cles to its use in the various energy sectors.

1.7
The EESC therefore urges the Commission to create,
before the end of 2006, long-term prospects for investors and
to propose new, binding targets with regard to the market
share to be obtained by biofuels by 2020.

1.3
Bringing about an increase in the share of overall renew-
able energy represented by biomass is a key prerequisite for
enabling the EU to achieve its goal of having renewable energy
comprise 12 % of overall energy consumption by 2010. The
proposal to step up the promotion of the use of biomass is
therefore the right course of action and an essential step.

The proposal to close the gap in legislation with regard
1.4
to the use of
renewable energy for heating purposes is
expressly supported by the EESC. The only instruments avail-
able up to now at EU level have been the Directive on
promoting electricity produced from renewable sources and the
Directive on promoting biofuels.
that
heating accounts for some 50 % of overall energy consumption,
and in the light of the considerable potential of biomass as a
means of producing heating, the Commission is expected to
present a proposal on this subject before the end of 2006.

In view of

the fact

The scope of this proposal should, however, not be
1.5
confined to biomass;
it should also take account of other
renewable energy technologies used in heating and cooling
systems. Setting a concrete, binding target
for the EU to
achieve by 2020 would provide investors with security. The EU
should set a binding target of having at least 25 % of final
energy consumption met by energy produced from renewable
sources by 2020.

1.8
The funding provided up to now in the Seventh Frame-
work Programme should be substantially increased. The use of
in particular,
lignocellulose-based biomass and by-products,
should also be stepped up.

1.9
The existing Directive on the promotion of particularly
efficient cogeneration (1) should be broadened in order to give
priority to the use of biomass in cogeneration, provided that
the underlying conditions render this possible.

A horizontal approach should be adopted in respect of
1.10
the policy for increasing the use of biomass in the EU. Coordi-
nating agricultural policy, structural policy, regional policy and
energy policy with a view to enabling farmers to gain greater
access to the energy production market, too, may point the
way forward for competitiveness, environmental protection and
energy supply in Europe.

1.11
The EESC welcomes the fact that the Commission has
flagged up the need for transparent, reliable trade agreements.
Instruments providing for qualified market access, also in the
case of biomass products, should, however, be set up under the
WTO treaties. This is the only way to enable the embryonic
European production industry to have the opportunity to
develop.

1.12
should also be discussed in a European action plan.

The use of biomass in the production of materials

1.6
The EESC has some criticisms to make in respect of the
Commission's planned report on the use of biofuels and calls
for stronger measures to be adopted in this field. The use of

(1) Directive 2004/8/EC on the promotion of cogeneration based on a
useful heat demand in the internal energy market - OJ L 52 of
21.2.2004.

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1.13
The Commission and the Member States are called
upon to amend the Sixth Directive (2) on the harmonisation of
the laws of the Member States relating to turnover taxes with a
view to authorising Member States to apply a reduced rate of
value-added tax on materials and services in connection with
the use of heating and cooling systems powered by renewable
energy.

1.14
The EESC calls upon the EU Member States and the
Commission to ensure that a minimum share of the resources
of the EU Structural Funds is set aside for investment in the use
of biomass and other renewable sources of energy. The EESC
also advocates earmarking minimum shares in the European
Agricultural Fund for Rural Development (EAFRD) for such
investment. The share of funding set aside for investment in
this field should increase and amount to 10 % of Structural
Funds resources — as an average figure for the Member States
— by the end of the planning period in 2013.

1.15
The EESC also believes that the decoupling of direct
payments, as part of the latest reform of the CAP, provides a
key prerequisite for stepping up energy plant cultivation. In the
EESC's view, there is scope for action to be taken in the short-
term within the framework of the CAP with a view to adjusting
the energy plant premium. The use of this instrument should
then also be made possible in the new Member States, in par-
ticular.

1.16
In addition to an ongoing monitoring of the extent to
which targets have been achieved, there is, in the EESC's view,
also a need to make it mandatory for the Member States to
draw up biomass action plans. This would make it possible to
identify and mobilise the potential of the various regions.

1.17
The EESC proposes that administrative barriers be
removed and that account be taken of renewable sources of
energy, for example in regional planning measures.

The EESC expects that the requirements in respect of
1.18
safe certification of the origin of products would already be
defined in a Biomass Action Plan. It draws attention to the
following requirements: sustainability criteria in respect of
products of EU origin; food sovereignty; and social and envir-
onmental standards to be met in order to gain qualified market
access.

The EESC welcomes the fact that, according to the
1.19
Commission, the same emission standards will apply to bioe-
nergy as apply to fossil fuels.

The EESC foresees the development of a single Euro-
1.20
pean energy policy. Whilst there may be a degree of useful
competition between marketing systems for renewable sources
of energy, those systems which have shown themselves to be
particularly cost-efficient and efficient as regards the extent to
which they have stimulated the development of new processes
should also be applied throughout Europe. A case in point is
the use of dynamic fixed price models which have already been
introduced under the renewable energy acts adopted by many
EU Member States.

(2) Council Directive 77/388/EEC of 17.5.1977 on the harmonisation
of the laws of the Member States relating to turnover taxes –
Common system of value added tax: uniform basis of assessment.

1.21
In the EESC's view, marketing measures cannot be
geared to long-term subsidisation but should rather seek to be
competitive and economically viable when external costs are
also taken into account.

2. Explanatory statement

renewable

The development of

2.1
sources of energy
continues to top the energy policy agendas of both the EU and
the following considerations:
its Member States because of
security of supply; the EU's increasing dependency on imports
of oil and natural gas; rising oil prices; and the obligations to
cut greenhouse gas emissions.

2.2
The goals set out in the Directive on the promotion of
electricity produced from renewable energy sources and those
set out in the Directive on the use of biofuels, will not be
achieved unless more far-reaching measures are taken. The EU
will also fail to realise its overall goal of doubling the market
share of renewable energy to 12 % if it persists with a ‘business
as usual’ scenario. A major reason for this is that a large part of
the energy required to meet this target would have to be
produced from biomass and the development of this market is
lagging behind expectations.

The market share of all

2.3
forms of renewable energy
remains at a persistently low level; the share of renewable
energy in the overall energy mix of the EU is likely to be only
9 % to 10 % by 2010, rather than the target figure of 12 %,
unless appropriate measures are taken. The Commission has
least
therefore submitted a biomass action plan which at
announces a number of
further initiatives in this key area
which has up to now been strategically neglected.

life of

Investments in energy utilisation are always long-term
2.4
investments. A newly-completed power station will have an
operational
in excess of 30 years. Uncertainty over
trends in oil and gas prices, in contrast to the high level of
predictability of raw material costs in the biomass sector, repre-
together with the effects of aspects such as climate
sent,
change, a key economic reason for promoting this technology.
Furthermore, the aim is not to engage in long-term subsidisa-
tion of systems but rather to develop systems which are
competitive when also taking account of external costs.

2.5
In contrast to the expected price increases for conven-
tional fuels, renewable energy technologies are providing ever
better value for money as result of falling investment costs
brought about by technical progress and mass production.

Cost

energy

2.6
and
comparisons between renewable
conventional or nuclear energy are usually inadequate. In many
cases comparisons are made between costs in respect of power
stations built by former state-monopoly generating companies,
the value of which has already been written off, and costs in
respect of newly-installed capacity using renewable technolo-
gies. Furthermore, the external costs of conventional or nuclear
technologies, such as damage to the environment or insurance
benefits provided by the State in respect of power stations, are
also not reflected in energy prices.

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2.7
In its action plan, the Commission sets out more than
20 measures, most of which are to be implemented from
2006. With regard to the use of biofuels in transport, a
number of preliminary measures have to be taken prior to the
introduction of obligations under which oil companies would
have to add a given percentage of biofuels to their conventional
fuels.

2.8
In its action plan, the Commission announces that it
will present a report in 2006 on a possible revision of the
biofuels Directive; in this report the Commission will examine
the implementation of this Directive in this EU Member States.
The current market share of biofuels in the EU is 0.8 %; it is
therefore highly unlikely that the target of a market share of
5.75 % for the EU as a whole,
laid down in 2003, can be
attained by 2010.

2.9
Under the action plan the scope for improving fuel stan-
dards is to be examined with a view to promoting the use of
energy from biomass in transport, electricity generation and
heating. Investment in research, particularly into the produc-
tion of liquid fuels from wood and waste materials, is also to
be promoted, as is a campaign to inform farmers and owners
of forests about energy crops. The Commission also intends to
draw up legislation to promote the use of renewable energy for
heating purposes.

2.10
According to estimates made by the Commission, if
the measures foreseen in the action plan are implemented,
biomass use could be increased to about 150 Mtoe by 2010 (as
opposed to 69 Mtoe in 2003) without intensifying agricultural
production and without significantly affecting domestic food
production. According to the forecast made by the Commis-
sion, this could, in turn, bring about a reduction in greenhouse
gas emissions of 206 million tonnes CO2 per year. Between
250 000 and 300 000 jobs would also be created — mostly in
rural areas — and the EU's dependence on imported energy
would be reduced from 48 % to 42 %.

2.11
Assuming the price of a barrel of crude oil to be $54,
the Commission estimates that the directly measurable cost of
the projected increase in biomass use would be EUR 9 billion
per year — EUR 6 billion for biofuels and EUR 3 billion for
biomass used in electricity generation. This is equivalent to an
increase of about 1.5 cents per litre of petrol and 0.1 of a cent
per kWh of electricity.

3. General comments

The EU will not achieve the goals which it has set with
3.1
regard to expanding the use of renewable energy unless further
measures are taken. The EESC welcomes the Biomass Action
Plan and notes that, in setting a number of additional inter-
mediate objectives, such as a 15 % overall share for renewable
energy and an 8 % overall share for biogen fuels by 2015, the
Spring Summit of Heads of State and Government signalled
that an ambitious policy for the use of renewable sources of
energy is to continue to be pursued. The decision taken by the
European Parliament to set a target of a 25 % overall share for
renewable energy sources by 2020 demonstrates that there is a
growing determination to bring about a redirection of energy
policy in the EU.

innovative

technologies — the

A further barrier is the fact that — as is the case with
3.2
many other
technologies
employed in the case of renewable energy sources often still
have to contend with a lack of confidence on the part of inves-
tors, governments and consumers; this can be put down to
ignorance of the technical and economic possibilities offered by
these sources of energy. In the EESC's view, there is a consider-
able need for information and further training not
in
respect of users and consumers but also in the R & D sector;
the Biomass Action Plan should address this need more inten-
sively.

just

3.2.1
The EESC also notes that there is frequently a concen-
tration of enterprises in the energy sector and points out that
this does not always chime with the need for a rapid introduc-
tion of innovatory techniques and procedures. The EESC draws
attention to the fact that, against the background of the current
business structure, new impulses, which often arise in small
and medium-sized enterprises, are not adequately exploited. It
calls upon the Commission to put
forward proposals for
improving this situation.

3.3
Increased use of biomass could not only bring about a
substantial reduction in the EU's dependence on energy imports
but also make a considerable contribution towards the realisa-
tion of the Lisbon strategy and the climate protection objec-
tives. The use of biomass also tends to promote decentralised
structures and thus also to encourage rural development. Parti-
cularly in the case of the new EU Member States, where a
considerable proportion of the workforce is employed in agri-
culture, the use of biomass provides major scope for diversi-
fying sources of income and safeguarding jobs.

The EESC draws attention to the fact that Europe is
3.4
currently the leading player in a number of areas of bioenergy
technologies. The EU economy is dependent upon the develop-
ment and export of new technologies. Innovatory procedures
and products based on regrowing raw materials provide the
basis for enabling the EU to lead the world in the technologies
of the future. It is therefore of key importance to the economic
development of regrowing raw materials in the EU that the
requisite basic political conditions are in place. The establish-
ment of these structures should also go hand–in–hand with
measures to support the export of bioenergy technologies to
countries outside the EU.

The EESC recognises the considerable labour-market
3.5
potential generated by the implementation of
the Biomass
Action Plan alone. The MITRE (Monitoring and Modelling
Initiative on the Targets for Renewable Energy) Synthesis
Report of 2003 established that, if the EU were to adopt an
ambitious raw-material strategy based on renewable sources of
energy, almost 2.5 million net additional jobs would be created
by 2020 in EU-15 alone. It was forecast that some two-thirds
of these jobs would be created in the biomass sector. This will
give rise, on the one hand, to an additional need for highly
skilled employees, particularly in the fields of R and D. The
number of employees required is estimated at 400 000. At the
same time there will, on the other hand, also be a need for
employees having low or modest basic skills. The EESC calls
upon the Commission to investigate the prospects for the EU
labour market in the period up to 2020 which would be
opened up by an ambitious expansion of the use of biomass
and renewable energy sources.

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In the EESC's view,

3.6
it is essential to set out binding
long-term political targets in order to trigger investment and
restructuring. The Biomass Action Plan fails to set such targets.
The Commission is therefore urged to define, as soon as
possible, concrete objectives concerning the use of biomass or
other renewable energy sources. Binding European targets,
covering the period up to, at least, 2020, should be defined in
respect of electricity generation, heating and transport; these
targets should be realistic but ambitious. A binding target
should be set of having at least 25 % of final energy consump-
tion met by energy produced from the abovementioned
sources by 2020. The existing biomass potential
in Europe,
particularly as regards by-products, together with the potential
amount of land available, once it is put to different use to meet
changed demand structures, may make it possible to pursue
this course of development. The EESC would point out that the
USA is implementing, by means of an energy conservation act,
its own similarly high targets for the long-term use of biomass.

3.7
The EESC supports the cautious assessment of the raw-
material basis (amount of biomass required) for implementing
the Biomass Action Plan; it is expected that, during the plan-
ning period,
these requirements will still not give rise to
competition with agricultural raw material production. In the
long term, it may be assumed that productivity will increase
and that there will be a drop in the level of food consumed in
Europe. At present a large proportion of arable land in the EU
is required for keeping livestock. There is, however, on the
other hand, a world-wide shortage of arable land. Considerable
demands will therefore have to be placed on the development
In this
of efficient processing and conversion technologies.
context, the EESC is critical of the ‘balanced approach’ advo-
cated by the Commission with regard to the securing of
supplies at international level, particularly supplies of the basic
raw materials for biofuels. In this field cheap imports into the
EU may endanger the production of basic food supplies in
other parts of the world, whilst also holding back technological
developments in Europe.

In spite of the different forms of energy requirements
3.8
and differences as regards the biomass supply basis in Europe,
the EESC expects a Biomass Action Plan to put forward views
on how marketing systems can be developed. In this context
and with a view to promoting electricity generation from
renewable sources of energy, including biomass, the measures
which have been shown to be the most efficient in terms of
both cost and development are models for feeding electricity
into the grid and premium models, such as those developed in
Germany. In its communication on electricity from renewable
energy sources (3), the Commission has already drawn attention
to this point. The basic financial conditions are not, however,
the only decisive factors with a view to expanding the use of
renewable sources of energy. At least four parameters have to
be met in order to ensure successful expansion in this field.

3.9
These conditions are as follows: an efficient financial
incentive model; guaranteed, fair conditions in respect of access
to the grid; transparent administrative procedures; and public
acceptance. Only if these four conditions are fulfilled at the
same time will it be possible to achieve a significant rate of
growth as regards the generation of electricity from renewable
energy sources. Electricity generation accounts for some 20 %
of the EU's energy requirements.

(3) Communication of 7.12.2005, COM(2005) 627 final.

The EESC endorses the conclusion, set out

in the
3.10
abovementioned Commission Communication,
to the effect
that it is too early at present to bring about complete harmoni-
sation of aid models for promoting electricity from renewable
energy sources. The EESC does, however, call upon both the
Commission and the Members States to make preparations for
the introduction throughout Europe of
the most effective
components of such models.

3.11
The Commission is called upon — in line with Direc-
tive 2001/77 (4) — to monitor the above-mentioned conditions
in the Member States and, if necessary, to insist on their intro-
duction.

3.12
The EESC endorses the Commission's appraisal of the
role to be played by biomass in implementing Directive
2001/77. In the Action Plan the expansion of cogeneration,
particularly when also utilising biomass, is described as a key
prospect for future development. The EESC calls for the Direc-
tive to be brought into line with the cogeneration Directive. It
the
should be stressed that, over
impending high level of investment in replacing power stations
will provide an opportunity for expanding cogeneration in
Europe. This will, as is widely acknowledged, promote more
in close proximity to the
decentralised electricity generation,
consumer. The EESC does, however, draw attention to the fact
that the Biomass Action Plan fails to put forward any views on
how to ensure that electricity producers, including those produ-
cing energy from biomass, can be given access, on a non-discri-
minatory basis, to electricity grids.

two decades,

the next

that

the fact

3.13
50 % of Europe's energy requirements is used for the
production of heating. Despite the considerable potential of
biomass with regard to the production of heating, heating
produced from this source probably accounts for less than
10 % of the market at the present time. The EESC therefore
expressly welcomes the proposals set out in the Action Plan. In
in heating systems and
investment
view of
building systems is very long-term investment and, to a certain
extent, also capital-intensive, the EESC calls for a prompt start
to be made on implementing the proposed measures. The
proposal for a legislative initiative in respect of heating and
cooling systems should be extended to take the form of a
Directive on the promotion of heating and cooling produced
from all renewable sources of energy, i.e. including solar energy
and geothermal energy. In addition to the measures proposed
by the Commission, a future Directive should lay down binding
national objectives which should take account of differences as
regards natural resources and existing capacities.

The EESC deplores the fact that hardly any reliable
3.14
statistics are available relating to heating; if there were to be a
uniform system throughout Europe for monitoring the use of
heating, this would enable the EU as a whole to plan the use of
resources more effectively. As regards the conversion of district
heating networks to use biomass as fuel, the EESC underscores
the Commission's appraisal in respect of the importance, the
development and the safeguarding of these networks. In the
new Member States,
there is a considerable
number of such networks which need to be safeguarded.

in particular,

(4) Directive 2001/77/EC of 27.9.2001 on the promotion of electricity
produced from renewable energy sources in the internal electricity
market.

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The existing Directive on the energy performance of buildings
should be implemented as soon as possible in all Member
States and endeavours should be made to amend the Directive.
The field of application of the Directive should be extended to
include all buildings, including those having a surface area of
less the 1 000 m2. Priority should be given to the use of decen-
tralised energy systems based on biomass. The EESC endorses
the observations made in the Action Plan on the building of
new district heating systems — and the safeguarding of existing
systems — using biomass to produce heat and, in particular,
heat and power.

The EESC welcomes the points made by the Commis-
3.15
sion in the Biomass Action Plan with regard to the existing and
future emission standards (and the Directive on particulate
matter) in connection with the use of biomass. The same stan-
dards apply in the case of the production of heating and electri-
city generation and also the use of fuels.

4. Specific comments

Although fuels account

4.1
for only 20 % of Europe's
energy needs, they derive, almost exclusively, from imports of
fossil-based raw materials. This fact justifies the considerable
amount of space devoted to fuels in the Biomass Action Plan.
In the EESC's view, the Commission's activities in this field, as
described in the Biomass Action Plan, bear the hallmark, to an
excessive degree, of pressure to come up with successful propo-
sals without delay. Too much emphasis is placed on imports of
marketable fuels and too little importance is attached to the
new dependence on imported products and to effects on the
environmental and social balance in the new energy-producing
states. The EESC requests the Commission to examine whether
this strategy, as set out in the Action Plan, might not actually
have the effect of delaying the development of sustainable
European solutions.

instrument has

4.2
In the biofuel sector, tax reductions or tax exemptions
have been shown to represent the most effective aid measures.
This
investments
tailored to regional requirements. The Member States should
continue to have this option available to them. The Action Plan
fails to make this point clear.

in particular,

facilitated,

4.2.1
High priority should be attached in the R & D sector
— and therefore also in the future implementation of an EU
biofuel strategy — to the use of substitute natural gas (SNG), in
addition to biomass-to-liquid (BTL) fuels. In comparison with
biodiesel produced from oil-bearing plants, biogas has a five
times higher energy yield per ha. SNG has a high level of
output per area unit and is at an advanced stage of develop-
ment; the use of this fuel does,
in principal, also make it
possible to produce fuel, power and heating at the same time
in decentralised SNG plans.

4.3
The EESC supports the Commission in its endeavour to
formulate a binding target of a 5.75 % market share for
biofuels by 2010. It welcomes the fact that the 2006 Spring
Summit of Heads of State and Government set an intermediate
objective of 8 %, to be achieved by 2015. The EESC does,
however, note the lack of a strong commitment on the part of
the economic enterprises concerned, the Commission and the
Member States to make the urgently necessary quantum leap as
regards the achievement of more efficient transport systems. At
this juncture the EESC welcomes the proposals set out in the

Action Plan for removing the various forms of discrimination
against biofuels and the proposals in respect of standardisation.

4.4
The use of biomass should be substantially strengthened
under the Seventh Framework Programme for Research. One of
the objectives in this context must be to make renewable
energy sources competitive. The EESC draws attention to the
fact that a paradigm shift in research policy towards research
into renewable resources is of decisive importance to economic
development in Europe. The EESC expects to see more binding
statements issued in this context, also in the Biomass Action
Plan. The EESC underlines the fact that the main areas in which
development is lagging behind are not the supply of biomass
but rather in the availability of technologies for producing
marketable products.

In principle, however,

4.4.1 With a view to developing the use of biomass,
including its use for the production of materials, it is also often
advisable to adopt an approach based on fractions of biomass
and utilisation cascades.
the decisive
factors are market prices and production costs and future esti-
mates in respect of these factors. By way of example, bearing in
mind that there is no market for processed wood products, it is
generally more advisable and more effective to make use of
wood for the direct production of heating or energy, rather
than processing it into fuel by means of a long BTL process
involving energy losses. In the EESC's view, the Action Plan
should adopt a more differentiated approach in this context
and thus attach greater importance also to the use of biomass
for the production of heating.

4.5
The EESC expects that the Council and the Commission
will give high priority, also in the context of the allocation and
distribution of resources from the Structural Funds in the
Member States, to expanding investment in renewable energy
sources and,
in particular, biomass. A mandatory minimum
share of Structural Funds resources allocated to the EU Member
States should be earmarked for this type of investment. By the
end of the current planning period in 2013, the share of Struc-
tural Funds resources set aside for investment in this field
should amount
to 10 %, as an average figure for the EU
Member States.

In the context of the allocation of funding under the
4.5.1
second pillar (rural development) of the European Agricultural
Fund for Rural Development (EAFRD), renewable energy is
mentioned in the strategic planning section, which deserves
overall endorsement. Particularly in view of the very limited
financial resources and in the light of the potential of rural
areas, steps should be taken to ensure that, in the case of this
funding, too, by the end of the planning period in 2013, a
minimum average share, for the EU Member States as a whole,
of 10 % is set aside for investment in renewable energy.

in the short-term:

4.6
The EESC draws attention to the statements made in the
Biomass Action Plan with regard to the impact of decoupling
on the cultivation of regrowing raw materials. The EESC
would, however, highlight the following opportunity to make
adjustment
the energy plant premium
(EUR 45/ha) in respect of 1.5 m ha, adopted as part of the
Luxembourg decision on EU agricultural reform (2003),
is
coming up for review at the end of 2006. The EESC calls upon
the Commission to consider whether the current value of the
premium is sufficient. The EESC considers that the current
application procedure is too bureaucratic and it proposes that

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administrative adjustment be made as a matter of urgency. As
things
stand at present, no application for energy plant
premiums may be made in the new accession states which
have opted for a simplified CAP procedure (eight out of the ten
new Member States). As part of the adjustments to be made
from the end of 2006, the EESC calls for these Member States,
too, to be given the possibility of having access to this area
payment. As regards the amount of the premium, a separate
adjustment should be made for those locations which, as
results of the transformation process, are not entitled to receive
payments (5).

4.7
The EESC proposes that the EU Biomass Action Plan
makes provision for mandatory national and regional action
plans in the Member States. In view of the diversity of the EU
Member States and regions, this would be a step towards iden-
tifying the potential and shaping a policy and administrative
bodies accordingly.

4.7.1
The EESC draws attention to the fact that the Action
Plan fails to address the scope, shortcomings and impediments
with regard to the extended use biomass and of renewable
energy in the Member States and regions. A number of possible
remedies may be proposed, namely: making it mandatory to
take account of this issue in regional planning measures and
incorporate it in these measures; pinpointing and removing
discrimination in administrative bodies; concentrating the work
in the planning and construction phases on one administrative
department.

4.8
The EESC calls upon the Commission and the Member
States to amend the Sixth Directive (77/388/EEC) on the
harmonisation of the laws of the Member States relating to
turnover taxes with a view to authorising Member States to
apply a reduced rate of VAT on materials and services in
connection with the use of heating and cooling generated from
renewable sources of energy. By way of example,
some
Member States currently exempt gas and oil burners from
taxes, whilst levying the full rate of taxation on investment in
heating produced from renewable sources of energy.

4.9
There is, in the EESC's view, an urgent need to introduce
a European energy policy. When selecting the instruments
governing the introduction of renewable energy onto the
market, there is a need to find a balanced approach based not
only on competition between national systems but also invol-
ving dynamic progression towards introducing clearly the most
efficient rules.

Brussels, 17 May 2006.

4.10
The EESC also believes that there is a need to take
action without delay to introduce a certification system with
regard to the origin of biomass raw materials. This is the only
way to avoid negative balance sheets in respect of the environ-
ment and climate. The following requirements should be laid
down (6):

— cultivation of regrowing raw materials should be subject to
the same principles of good professional practice as food
production;

— even after having been used for growing non-food raw
materials, the land concerned must remain suitable for food
production;

— regrowing raw materials should be cultivated on land that
is already being used for agriculture and on set-aside land,
including,
left
temporarily uncultivated, and their cultivation must not
lead to a reduction in permanent pasture;

for example, areas which reform has

— production should ideally be in regional or local cycles so

as to reduce transport;

— ecologically valuable land should be reserved for nature
conservation and managed in accordance with conservation
goals;

— raw materials that demonstrate a good ecobalance should

be both promoted and cultivated;

— special attention should be paid to the achievement of

closed food cycles.

4.11
The following requirements should also be included in
the certification process in respect of the international trade in
biomass and biomass products:
food sovereignty (which
implies that ensuring security of food supply takes precedence
over the cultivation of cash crops); social and environmental
standards in respect of production; no clearing of primeval
forests. The EESC calls upon the EU to ensure that these criteria
are also incorporated into WTO rules.

4.12
The EESC calls upon the Commission to give its
support, in the Biomass Action Plan, to the creation of an Inter-
national Renewable Energy Agency (IRENA) and also to pay
greater heed in the Action Plan to the issue of transparency in
the international raw materials trade and industry.

The president

of the European Economic and Social Committee

Anne-Marie SIGMUND

(5) See NAT/288, point 3.2.4.2.

(6) See NAT/288, point 3.7.