Click here to see the original letter in Polish, with the list of signatories.
Warsaw, 27 July 2020
To: 1. Mr. Michał WośMinister of Environment
2. Mr. Tomasz GrodzkiMarshal of the Senate of the Republic of Poland
Subject: Government bill amending the Renewable Energy Sources Act (Print Nos 455 and 480), adoptedby the Sejm on 16 July 2020, introducing a definition of ‘energy wood’.
In our assessment, the plan of wider use of wood from Polish forests as fuel in power plants is extremely harmful from the perspective of current knowledge about nature protection and forest biology. The majority of Polish forests already resemble wood plantations and are devoid of key forest species. We anticipate that the proposed amendment to the RES Act will deepen the biodiversity crisis in Polish forests.
The draft has been prepared without any assessment of its effects on wildlife and biodiversity, and no experts in nature protection and forest biology were involved in the process. In view of these facts, we request that the legislative work be suspended and that a detailed environmental impact assessment of the proposed amendments to the RES Act be carried out.
Justification: The negative environmental impact of the proposed amendments to the Renewable Energy Sources Act and the introduction of the definition of “energy wood” result primarily from the type of wood material which will be allowed to be burned in power plants as biomass. This is clearly stated in the communiqué of the State Forests: ‘Energy wood will therefore include raw material of the worst quality […] First of all, it will be wood from sanitary cuttings, i.e. removal of dead or dying trees […] and often also trees felled or broken by storms (uprooted and broken trees)’. Full text available at: bit.ly/OZE_explaining.
State Forests specify clearly that deadwood and dying trees will be burned. Meanwhile, scientific research unequivocally shows that these very trees are crucial for preservation of biodiversity, as they provide hundreds of forest species with micro-habitats necessary for feeding, development and shelter.
In dying trees, more often than in healthy ones, hollows are formed (e.g. as a result of branches having been broken or in branch forks, also cavities made by woodpeckers) and one finds breakages, stem deformations, niches behind partially stripped bark, cavities inside the stem etc. These micro-habitats are inhabited by thousands of invertebrate species (including those rare and considered ‘beneficial’ such as species preying on bark beetles), which can find suitable living conditions (humidity, temperature, hummus substrate, etc.) only in such places. In turn, these invertebrates constitute an important element of the forest trophic chain, providing food for other invertebrates, amphibians, reptiles, birds and mammals. The hollows in dying and dead trees serve as refuge and breeding sites for rare mammals (e.g. around a dozen species of bats), several dozen species of birds, including ones which are rare and disappearing from Poland.
The second category of ‘energy trees’ are to be trees felled or broken by storms. Numerous domestic and foreign studies clearly show that removing trees damaged by storms, fires and bark beetles from the forest brings more losses than benefits: it negatively affects not only forest biodiversity, but also the regeneration rate of the damaged ecosystem. Dead and damaged trees left in forests provide shelter to many species, maintain a suitable microclimate and encourage a new generation of trees to regrow insuch places. On the other hand, removing them aggravates the effects of storms or bark beetle infestation: It creates open ground exposed to the sun, which becomes dry, as a consequence of which forest organisms die, and trees grow more slowly.