Biofuelwatch response to Greek government consultation about changes to forest management, 21st March 2025
I am writing on behalf of Biofuelwatch, a European/US non-profit organisation which has been researching and informing about the impacts of different forms of large-scale bioenergy since 2006.
We have been made aware of three Ministerial Decisions on forest management in Greece which are open for consultation. We understand that those three decisions, together, would hand management of forest ecosystems in large areas of Greece over to so-called Hybrid Cooperative Schemes, which include wood processing industries, and which would be subsidied according to the amount of wood that they remove from forests and sell for biomass energy. The decisions being consulted on are being justified by claims that forests contain ‘excess biomass’ and that removing this biomass, i.e. younger trees, undergrowth and deadwood, will prevent or reduce the scale and intensity of forest fires.
In this submission, we wish to share our serious concerns about the proposals and to share evidence that shows that increased wood removals and logging for biomass energy has not had the desired effect of mitigating against wildfires elsewhere.
Strong and growing evidence that forest thinning for ‘fuel load reduction’ does not reduce but can instead increase fire risks and intensity
Wildfires are increasing in size and frequency worldwide, driven by the escalating climate crisis. High “fuel load” in forests is often blamed for fires, however, there is little empirical evidence that increased logging and removal of undergrowth and deadwood reduces fire risks, and we could find no evidence at all that increasing wood biomass energy use has such an effect. Instead, there is growing evidence from scientific studies to show that logging, including forest thinning meant to reduce ‘fuel load’ can and often does increase fire risks. The only exception are fire breaks in the immediate vicinity of housing.
For example, the authors of a 2022 peer-reviewed study looked at the evidence for forest management measures aimed at reducing fire risks in the western USA. Those measures include logging of live, dying and dead trees and the removal of shrubs. The authors highlight adverse impacts including “degradation of wildlife habitat, including endangered species habitat; aquatic impacts from an expansive road system; and logging-related carbon emissions”. They further warn that the existing trend is towards more intense fires in heavily logged areas, and that this trend can be expected to continue.
Authors of a 2020 peer-reviewed study carried out an empirical analysis of stand history data from forests that had burned during wildfires in south-eastern Australia in 2009. They found that, in forests dominated by Ash trees, thinning had no impact on forest fire risks. In mixed-species forests, thinning reduced fire risks in young stands, but actually increased in older, i.e. more mature stands. Thinning increased fire intensity in all stands, regardless of their age. They list various mechanisms through which forest thinning can increase fire risks: Forest thinning may “dry the forest floor due to both the loss of mesic understorey elements like tree ferns (which are sensitive to logging operations… and changes in microclimate, such as increased penetration of light to the forest floor”. It “may also increase air movement through a forest, thereby potentially facilitating the spread of fire through the forest”.
Authors of a 2016 peer-reviewed literature review looked at whether protected forests with less logging in the western USA had greater fire intensity than forests that had been more intensively logged. They looked at data related to 1,500 fires affecting 9.5 million hectares between 1984 and 2014, and at four different levels of forest protection. They found that overall forests with the highest level of protection, i.e. the least logging, had the least fire intensity.
The US-based John Muir Project has summarised further evidence from the USA showing thinning forests does not result in reduced fire risks.
Another piece of evidence comes from Portugal, another country affected by a worsening wildfire trend, with a similar, Mediterranean, climate as Greece. Wood biomass plants have been promoted and subsidised based on the belief that their demand for wood will lead to reduced ‘fuel load’ in forests and thereby wildfire risks. In 2024, Portuguese environmental organisations studied the correlation between the extent of wildfires on the one hand, and the increased demand for wood for biomass energy on the other hand. They looked both at national trends, and at trends in the sourcing area of a particular biomass plant, the Fundão Biomass Power Plant in central Portugal. Their report shows that, since the commissioning of the Fundão Biomass Power Plant, the area of wildfires, and especially of forest fires has continued to increase unabated within a 50km radius of that plant. At the national level, too, investments in a significant new demand for biomass energy has made no dent in the continued increase in the area of forest fires. The authors of the report noted that the operators of the Fundão Biomass Power Plant preferred using wood from whole mature trees, especially trees that had been partially charred during fires, because such wood has a higher calorific value than residues, undergrowth, etc. The same is likely true for other operators of biomass plants.
Forest thinning and deadwood removal seriously harm biodiversity and the climate
Dying and dead trees, which would be widely removed under the ministerial decisions being consulted on, provide micro-habitats for thousands of invertebrate species which, in turn, play a vital role in the food chain on which reptiles, birds, amphibians and mammals depend. Hollows in dead and dying trees provide shelter and nesting sites for birds (such as woodpeckers) and bats. Deadwood left in the forest further plays a vital role in replenishing and increasing soil carbon.
The EU Nature Restoration Directive requires restoration measures “to enhance the biodiversity of forest ecosystems across the Union, including in the areas not covered by habitat types falling within the scope of Directive 92/43/EEC”. Standing and lying deadwood are amongst the biodiversity indicators listed in the directive, for which improvement is required by 2030 (Article 12).
Furthermore, the 2024 Greek National Inventory Report submitted to UNFCCC states: “Net removals from Forest land show an upward trend that is attributed mainly to the reduction in fellings. The sink capacity of Forest land has increased from -1.31 Mt CO2 eq in 1990 to -2.19 Mt CO2 eq in 2022.” The ministerial decisions being consulted on will, if implemented at scale, likely reverse this positive trend, reducing the amount of CO2 sequestered by forests or even turn forests into a net source of CO2 emissions, as has happened already in several EU member states including Germany.
Conclusion:
We urge the Greek government to reconsider and reverse the plans set out in the ministerial decisions being consulted on. Increased logging and deadwood removal risk worsening, not reducing fire risks and will inevitably cause severe harm to biodiversity while increasing Greece’s overall greenhouse gas emissions by reducing forest carbon sequestration.