This Tuesday [Dec 3, 2019], the Dutch Senate will discuss the Coal Act.[1]That states that within five to ten years power stations will no longer be allowed to burn coal because of the CO2emissions. Energy company RWE is therefore switching to biomass for its power stations. For this they use compressed wood sticks, so-called pellets. Opponents say that these are made from whole trees. Because wood emits more CO2 during burning than coal, the problem becomes worse. No, the proponents say, pellets are made from waste that is otherwise burned anyway, so that CO2 does not count.[2]What are pellets really made of?

Video’s abound that show how giant machines cut entire forests in the US. A stream of trucks then drives the logs to the pellet factory.[3]But perhaps those videos are selective and all show one and the same forest. We need quantitative data from reliable sources. Those exist.
The largest pellet manufacturer in the world, the American company Enviva, reports every quarter what their pellets are made of.[4]On average, that is four fifth trees and one fifth waste.[5]Half of the trees consist of pine and the rest of hardwood, especially oak.[6] The RISI report for the American wood and paper industry reported five years ago that three quarters of American pellets were made from trees.[7]That agrees with the Enviva figures. Proponents say no one makes pellets from whole trees, because trees yield more when converted to sawn wood. But the million-dollar subsidies for biomass have made that obsolete. According to the RISI report, the market price of freshly harvested trees at that time was $11 per green tonne, but pellet manufacturers offered $ 26 to $ 53 per tonne.[8]The price was boosted by the subsidies.[9]If energy companies receive no subsidies, they cannot even meet the manufacturing costs of pellets, so production stops and the trees remain in the forest. In the Netherlands, the import of pellets also goes up and down with the subsidies. That is why the Netherlands did not import pellets from the US in 2018, as Minister Wiebes recently stated in the House.[10]In 2018 we were just in between two subsidy rounds. What Wiebes did not say is that imports are now rising rapidly thanks to new billion-dollar subsidies.[11]
Proponents say that pellets are made from waste. However, the reports from pellet producer Enviva show that less and less waste goes into their pellets and more and more trees. In 2016, pellets consisted of 25% waste and now 18%. If there is a shortage of waste, it becomes even more unlikely that our power stations will run on wood waste. Indeed, a report from the University of Montana shows that in the woody Northwestern states of the US. hardly any waste wood is available.[12]It is all used up for paper and board, chipboard or as a fuel in the sawmills. Mechanization and rationalization result in less and less wood waste; in 1965, 14% of the harvested forest ended up as waste and, fifty years later, only 3%. That explains why Enviva is putting more and more trees into its pellets. The pellet manufacturers do offer the highest price for what is left of waste, so for chipboard, new trees are now being felled. Converting waste to biomass therefore indirectly leads to harvesting of more forest.
The whole idea that modern coal-fired power stations can run on wood waste is nonsense anyway. Bark, leaves and branches contain too much ash and dirt that clogs the ovens; large power plants require clean tree trunks![13]That is why a Belgian pellet manufacturer emphasized in a hilarious PR film that their pellets are mainly made from logs - from Dutch forests.[14]
American pellets are also mainly made from tree trunks. Reports from the EU,[15]the US Department of Agriculture,[16]Yale University[17]and the English Royal Institute for International Affairs[18]confirm that.
And pellets from the Baltic states, are those made from wood waste? Estonia houses the second pellet manufacturer in the world, Graanul. It also processes entire trees. The amount of waste that is released during regular timber harvesting is far too little to satisfy the fuel requirements of coal-fired power stations. It takes a forest five times the size of the whole of Estonia to provide enough waste wood to fire three coal-fired power plants in the Netherlands.[19]On satellite photos, forests in Estonia are declining rapidly[20], eyewitnesses report about cutting of primeval forests, and recently 35 forest protection organizations from Estonia and the US wrote a well-documented letter begging minister Wiebes and the House of Representatives to stop this.[21]
The only way to produce enough pellets is massive cutting of trees. How can producers claim that their pellets are made from waste? Here is how this works: if the price for wood for pellets is high due to the subsidies, the forest owner harvests an entire forest tract, removes a number of straight trees for saw wood and names the rest 'waste'. Pellets are made from this and are sold for good money.
Without the subsidies, that forest tract would have remained standing, but because of subsidies, the demand for pellets is now rising faster than the demand for saw wood.
A final argument for the sustainability of biomass is that it is certified with strict certification systems. But that is also not correct. First of all, the official Dutch regulations allow biomass to be made from trees.[22]In addition, the certification is a jungle (the SER Council is supposed to bring order into this next year). In the meantime, in order to keep supplies going, the Netherlands allows wood with less sustainable certificates.[23]
If the law banning coal leads to coal being replaced by biomass, it will lead to more instead of less CO2 emissions and to the destruction of forests. That is why a prohibition on wood burning should be coupled with the coal law. That means pulling down coal-fired power stations and huge expenses. I wish the Senate much wisdom.

[2] House of Representatives, November 19, 2019, MinisterWiebes: Answer to questions about the use of biomass as an energy source. "Partly as a result of the strict sustainability requirements, the wood pellets that are used in the Netherlands in practice consist of the inevitable residual flows from the regular production of wood."
[5] Waste is described as "sawdust, shavings or residuals from wood manufacturing" or "mill and industry residues". Furthermore, small quantities (<1%) of "Arboricultural sources" or "Landscaping and arboricultural activities". I added that to the waste.
[6]; Quarterman, E., and Keever, C. (1962). Southern Mixed Hardwood Forest: Climax in the Southeastern Coastal Plain, U.S.A. Ecological Monographs 32, 167–185.
[7] Walker, S. (2015). An Analysis of UK Biomass Power Policy, US South Pellet Production and Impacts on Wood Fiber Markets: Prepared for the American Forest & Paper Association (Boston).
[8] RISI report
[9] In this case it concerned British subsidies; the UK was and is the largest buyer of wood pellets for coal-fired power stations
[11] “Export volumes to the Netherlands, the fourth largest importer of U.S. wood pellets with 2.3% of market share, more than tripled as the country returned to co-firing at the end of 2018.”
[12] Erik Berg, Todd Morgan, Eric Simmons (2016). Timber Products Output (TPO) - Forest Inventory, Timber Harvest, Mill and Logging Residue - Essential Feedstock Information Needed to Characterize the NARA Supply Chain (University of Montana Bureau of Business and Economic Research). P. 21.
[13] Brack, D. (2017). Woody Biomass for Power and Heat (London (UK): Chatham House - the Royal Institute for International Affairs). “various types of roundwood are generally the main source of feedstock for large industrial pellet facilities. Forest residues are often unsuitable for use because of their high ash, dirt and alkali salt content.”
[14] Ecopower CVBA: This is how sustainable Ecopower pellets are made in our factory in Ham.
[15] Strange Olesen, A., Bager, S.L., Kittler, B., Price, W., Aguilar, F., European Commission, Directorate-General for the Environment, COWI, and Pinchot Institute for Conservation (2016). Environmental implications of increased reliance of the EU on biomass from the South East US: final report. (Luxembourg: Publications Office).
[16] Henry Spelter,  Daniel Toth. North America’s Wood Pellet Sector. USDA 2009, p 7: ‘Future growth of pellet manufacturing will inevitably have to spread to alternative fibers, chiefly roundwood, as that resource is available in concentrated volume in compact areas.’ p 8: ‘Long-term growth of wood as fuel ultimately means the need to use roundwood’
[17] Drouin, R. (2015). Wood Pellets: Green Energy or New Source of CO2 Emissions? "not enough of such waste wood exists to feed the growing demand for wood pellets" "the majority of the wood used at Enviva’s Ahoskie, N.C., mill comes from hardwood trees"
[18] Brack, D. (2017). Woody Biomass for Power and Heat (London (UK): Chatham House - the Royal Institute for International Affairs). “various types of roundwood are generally the main source of feedstock for large industrial pellet facilities. Forest residues are often unsuitable for use because of their high ash, dirt and alkali salt content.”
[19] If three Dutch coal-fired power plants switch to biomass, they need ten million tonnes of pellets per year. RWE Eemshaven ca 5 Mton, Amer (Moerdijk) and Engie / Riverstone (Maasvlakte) each around 2.5 Mton. What Uniper will do with its coal-fired power station on Maasvlakte is uncertain. Suppose that one in every thirty trees is cut down from a forest each year, leaving 15% of waste.
Calculation, "five times as large as the whole of Estonia":          
Wood pellets needed for RWE Eemshaven en Amer en Engie/Riverstone                            10 Mton/yr  
Forest area needed for RWE Eemshaven en Amer en Engie/Riverstone                       1,094 km2  
Forest area needed for RWE en Engie/Riverstone if 3.33
per y is harvested                 32,831 km2  
Forest area needed for RWE en Engie/Riverstone if 3.33
per y is harvested, only waste is used and 15% is waste:               218,872 km2  
Area of Estonia                     45,227 km2  
Forest area needed to provide 10 Mt of pellets     5 x all of  Estonia