AVEBIOM believes it is essential to increase the share of bioenergy in the energy mix in the new PNIEC

The Spanish Biomass Association considers it positive and necessary to broaden the objectives aimed at combating climate change and increasing the country's energy independence . However, biomass suffers from an inexplicable underestimation in both the current National Integrated Energy and Climate Plan (PNIEC) and the first draft for its update recently submitted by the government to the Eur .

Again, the target for electricity generation with biomass is unambitious (1.4 GW out of a total of 166.2 GW of renewables in 2030) and, in the thermal use of biomass, the plan does not even propose a specific target, expressed numerically.

While the draft plan rightly acknowledges the need to reduce forest fuel load to mitigate fires and facilitate firefighting, it does not present actions to utilize the resulting biomass, for example, as biofuel instead of fossil fuels .

Since the 1990s, in Spain only a maximum of 40% of the annual growth of wood in forests is utilized (according to the national forest inventories IFN 2, IFN3, IFN4), which has resulted in the stock of standing wood doubling.  

To facilitate the reduction of this excess of forest biomass, it would be very effective to establish a Roadmap with clear objectives for its sustainable use.  

AVEBIOM proposes the construction of at least 200 new heating networks using forest biomass , or, expressed in power: 2,800 MW, which would require the mobilization of 1,200,000 tons of biomass; the replacement of at least 500,000 obsolete heating units with modern biomass equipment, which would consume 530,000 tons of certified biomass; and the construction of 500 MW of electricity in medium-sized power plants (10-25 MW) strategically located in forest areas that need to reduce biomass density.

Regarding the energy recovery of pruning waste from woody agricultural crops , primarily olive groves and vine shoots, proposing its use in residential settings as wood chips and pellets is ill-advised. Agricultural activity in Spain generates almost 13 million tons of dry matter from herbaceous and woody residues each year, which could replace millions of liters of fossil fuels in industrial boilers (from 200-300 kW upwards) and be used as an energy source in new district heating networks and biomass power plants.

The use of minimally processed biomass allows for significant savings in greenhouse gases and energy by eliminating the drying, transport, and pelletizing processes. Furthermore, this biomass, free of impregnations and pollutants, is sometimes referred to as waste in the National Integrated Energy and Climate Plan (PNIEC), when in fact it is not .

Regarding particulate emissions linked to biomass , the draft attributes primary PM2.5 emissions to biomass as the main source of pollution. However, it is essential to distinguish between types of biomass and their use. Current boilers and stoves (meeting ecodesign regulations and fuel certification) have very low efficiency and particulate emissions, unlike obsolete devices.

In fact, current emission factors do not adequately assess modern boilers, something that needs to be updated as soon as possible, as has been done in other Eurcountries. 

Finally, the draft fails to mention the possibility of integrating carbon capture technologies into biomass-fired power plants and district heating networks (BECCS or biochar production) . This option is crucial for achieving negative emissions and generating renewable energy, as recognized by organizations such as the International Energy Agency.

The Spanish Biomass Association has submitted its comments regarding biomass and the measures proposed in the draft of the PNIEC.