Current biomass policy frameworks are not fit for purpose and require substantial changes to ensure they contribute to mitigating climate change rather than exacerbating it.
3. Sustainability Criteria
Chapter 1 highlighted the way in which the impacts on the climate of the use of woody biomass for energy vary significantly depending on the feedstock and the way in which the forest from which the feedstock is sourced is managed. One means of avoiding (or, at least, ameliorating) these impacts is to apply preconditions that biomass installations are required to meet before they are eligible for the regulatory and financial support afforded to renewable energy sources. This topic has been under discussion within the EU for several years, and the European Commission published proposed sustainability criteria for solid biomass in November 2016.
This chapter:
- Analyses the evolution of sustainability criteria for solid biomass in the EU, including the commission’s latest proposals;
- Summarizes the sustainability criteria applied to date in some EU member states;
- Looks briefly at sustainability criteria applied by governments outside the EU; and
- Analyses the sustainability criteria applied under voluntary schemes, in particular that of the Sustainable Biomass Partnership.
The EU
The EU’s 2009 Renewable Energy Directive contained sustainability criteria for liquid biofuels, designed to ensure that their use delivered significant greenhouse gas savings compared to the fossil fuels they replaced (mainly for transport). There was nothing similar for solid (or gaseous) biomass, however. Instead, the directive contained a commitment to report on the requirements for such a sustainability scheme by the end of 2009.
Over the following six years the European Commission changed its view several times. In 2010 it concluded that no EU-wide criteria for solid biomass were necessary; in 2013 that they were; in 2014 that they were not; and finally in 2014 that they were. Proposals were finally published in 2016. These changes in views took place against the background of disagreements between member states. Supporters of the introduction of sustainability criteria included the main importers of biomass for energy (the UK, Belgium and the Netherlands) as well as France, Germany and Poland. Opponents tended to be those mostly reliant on their own domestic production (Austria, Finland and Sweden) that feared the potential impact on their forest industries.132
The European Commission’s initial decision, included in a report published in 2010, that no binding criteria were necessary at the EU level was based on the wide variety of biomass feedstocks in use at the time, together with the low sustainability risks relating to domestic biomass production from wastes (municipal solid waste, post-consumer recovered wood, etc.) and agricultural and forestry residues, where no land use change occurred.133 Instead, member states desiring to introduce their own national schemes were encouraged to develop them in line with the directive’s requirements for biofuels. The life-cycle assessment methodology whose use it encouraged considers emissions from the cultivation, harvesting, processing and transport of the biomass feedstocks, and includes direct land-use change where the land has changed category since 2008 (e.g. from forest to annual cropland). However, the methodology does not account for changes in the carbon stock of a forest, foregone carbon sequestration of land or any indirect impacts on carbon stocks in other areas of land. The report was published when the focus of the debate on the sustainability of bioenergy was primarily on liquid biofuels rather than solid biomass, and in particular their direct and indirect impacts on land use.
A 2012 European Commission survey of the effect of national schemes found that, while 20 member states had introduced some sort of requirements covering the sustainable production or efficient use of biomass, the vast majority of these related to end-use efficiency, either requiring mandatory minimum efficiencies for the production of heat or electricity or both, or providing financial incentives to stimulate higher efficiencies or heat recovery.134 Only the UK had introduced regulations referring to the biodiversity and land-use-change criteria recommended in the commission’s 2010 report, though this did not include any criteria relating to changes in carbon stock on existing forest land. Against this background the commission became convinced that EU-wide sustainability criteria would be valuable and in 2013 a draft set was discussed internally. No agreement could be reached within the commission, however, so further development was halted.
In 2014 the European Commission reviewed the issue again and concluded that there was still no need for any EU-wide criteria since national sustainability schemes did not appear to be creating any internal market barriers and most (more than 90 per cent in 2012) biomass supply was sourced domestically, mostly from processing and harvesting residues.135
However, the discussions over the EU’s 2030 climate and energy package and the development of the European Energy Union, as well as the growth of imports of biomass for energy into the EU and the debates over the sustainability criteria for biofuels in the light of their increasingly clear impacts on forests (which ended with the decision to remove all support for land-based biofuels after 2020), highlighted the lack of consistency between the treatment of biofuels and of biomass. Accordingly, in 2014, the commission concluded once again that EU-wide criteria would be necessary to ensure genuine greenhouse gas savings and to allow for fair competition between the various uses of biomass.136 The biomass policy also aimed to help deliver sustainable management of forests, in line with the EU’s Forest Strategy. Published in 2013, the Forest Strategy included support for the cascading use of wood as a way of maximizing resource efficiency, implying that wood should be used in the following order of priority: wood-based products, extending their service life, re-use, recycling, bio-energy and disposal.137
New proposed criteria for solid and gaseous biomass were finally published in November 2016, as part of a substantial package of policies to support renewable energy, centring on a proposed revision of the Renewable Energy Directive. The proposed criteria, which apply to installations of capacity of 20 MW and greater, include the following requirements.138
- The country or forest from which the forest biomass was sourced has systems in place to ensure that harvesting is carried out legally, harvested forest is regenerated, areas of high conservation value (including wetlands and peatlands) are protected, the impacts of harvesting on soil quality and biodiversity are minimized, and harvesting is limited to the long-term production capacity of the forest.
- The country from which the forest biomass is sourced is a party to the Paris Agreement and has submitted a Nationally Determined Contribution to the UNFCCC covering emissions and removals from agriculture, forestry and land use ensuring either that changes in carbon stock associated with biomass harvests are accounted towards the country’s climate commitments or that there are laws in place to conserve and enhance carbon stocks and sinks. (If evidence for these requirements is not available, forest-management systems must be in place to ensure that forest carbon stock levels are maintained.)
- Minimum greenhouse gas savings compared to fossil fuels of 80 per cent for installations starting operation after 2020 or 85 per cent for installations starting after 2025 must be achieved. This relates only to supply-chain emissions, not to changes in forest carbon stock. (Suggested default values are provided for different types of feedstock and different transport distances.)
- Electricity must be produced from highly efficient cogeneration technology for installations starting operation three years after the date of adoption of the new directive (it is not clear whether this applies to old coal plants converting to or co-firing with biomass; and the delay is in any case subject to further discussion).
Member states are to be permitted to apply additional sustainability requirements over and above these EU-wide criteria. Proof of compliance with the criteria is to be provided by the plant operators, subject to independent auditing as defined by the member states. It is open to the European Commission to decide that voluntary schemes comply with the criteria (see below) and to member states to establish national schemes to do the same.
The impact assessment published alongside the draft directive explained the commission’s thinking behind the proposals. It fully recognized the climate impacts of changes in forest carbon stock, noting:
Recent studies have found that when greenhouse gas emissions and removals from combustion, decay and plant growth (so-called biogenic emissions from various biological pools) are also taken into account, the use of certain forest biomass feedstocks for energy purposes can lead to substantially reduced or even negative greenhouse gas savings compared to the use of fossil fuels in a given time period (e.g. 20 to 50 years or even up to centuries).139
While considering that most current biomass use in the EU confers substantial greenhouse gas savings – since the feedstock is mostly industrial residues, harvest residues and traditional fuel wood – the commission recognized the potential for change if demand continued to grow, including additional harvesting rather than forest residue removal and the increased use of small roundwood and stumps. ‘Hence, and as shown by a recent study… an increase in use of forest biomass for energy may lead to limited greenhouse gas savings or to an increase in emissions.’140 Modelling conducted for the study also showed that, in the absence of sustainability criteria or other safeguards, growth in the use of forest biomass for energy would result in zero or small additional greenhouse gas emission reductions by 2030, or even, because of changes in forest carbon stock, an increase. And if demand continued to grow to 2050, emissions would increase in all scenarios.141
Despite this, however, the European Commission concluded that it was not possible to include changes in forest carbon stock in the calculation of life-cycle emissions to be used for the minimum greenhouse gas savings requirements in the sustainability criteria. Pointing to the wide variation in estimates of the climate impacts, the difficulty in attributing greenhouse gas performance to specific consignments of forest biomass and the problems of evaluating the counterfactuals, it concluded that:
a reliable assessment of life-cycle biogenic emissions of specific consignments or pathways of forest biomass would be extremely difficult, notably because it would have to be based on subjective choices. In addition, it would pose difficulties linked to verification. Therefore, this option is discarded.142
Even in the absence of the inclusion of changes in forest carbon stock in the sustainability criteria, the models used in the impact assessment predicted that the proposals would lead to a slight reduction in net greenhouse gas emissions by 2030, though there was a chance of a slight rise by 2050.143 This was due mainly to a projected fall of 3.3 per cent in total demand for bioenergy by 2030, compared to business as usual, because of restrictions on sourcing from high-risk countries (a 45 per cent fall in imports into the EU was projected in one model, a 4–19 per cent fall in another) and of increased harvesting and use of domestic roundwood within the EU, which pushed up prices for wood products. The models are subject, however, to considerable levels of uncertainty.
The European Commission considered but discarded other options for constraining forest biomass use, including the following:
- The introduction of limits on the use of forest residues, in order to protect biodiversity and soil fertility. The commission considered that this would be too difficult given the degree of variability in local conditions and, in some regions, the need to remove residues to prevent fire. In addition, it considered that ‘forest residues are also normally not traded over a long distance and are not turned into pellets’.144 (This is notwithstanding the claims of biomass companies such as Drax.)
- Promoting the cascading use of wood, in line with the EU Forest Strategy. The commission considered that a single EU-wide approach was not appropriate given the different circumstances of each member state. Non-binding guidance on the cascading use of wood is expected to be published by 2018.145
- Applying sustainable forest-management requirements to all forest biomass, regardless of origin. The criteria proposed in the draft directive require countries or forests to have particular systems (for legality, the protection of high conservation value areas, etc.) in place rather than requiring operators to ensure that every consignment of biomass is verified as sustainably produced (probably via certification schemes). As the impact assessment explains, this is a risk-based approach designed to minimize costs to forest owners, many of whom are not certified under any forest-certification scheme.146
The draft directive, including the proposed sustainability criteria, has entered a period of debate and discussion between the European Parliament and member-state governments.
EU member states
Pending the development of EU-wide criteria, an increasing number of member states have developed their own for eligibility to subsidies or other support mechanisms.147 As noted above, many member states have possessed relevant requirements for some time, including the following:
- Requirements for minimum levels of efficiency; for example, France requires a minimum conversion efficiency of at least 75 per cent, which rules out anything other than combined heat and power (CHP) plants, whereas Spain gives higher levels of support to biomass plants achieving higher energy efficiency through cogeneration.
- The provision of greater levels of support for small-scale plants; examples include Finland and Germany.
- Encouragement for or requirements that feedstock be sourced from sustainably managed forests; examples include France, Germany, Hungary and Slovenia.
- Support for domestically sourced feedstock instead of imports; examples include Austria, the Czech Republic and Italy.
- Restrictions on certain types of feedstock. For example, France does not allow stemwood; in Hungary feedstock cannot be of higher quality than firewood and no subsidies are provided for bioenergy produced from stemwood of a diameter above 10 cm; and Poland only allows the use of forestry residues and requires a minimum (increasing) share of agricultural biomass.
For all member states, domestically produced or imported woody biomass is also subject to the EU Timber Regulation (995/2010, in force since 2013), which prohibits the placing on the EU market of products that have been illegally produced and requires companies that first place wood products on the EU market to have in place a system of ‘due diligence’ to minimize the risk of them handling illegal material. If fully enforced, this is likely to act as a constraint on the supply of woody biomass, in particular from Eastern European countries (including, possibly, some EU member states) and Russia.
To date, the most detailed sets of criteria have been developed in Belgium, Denmark, the Netherlands and the UK. In some cases these borrow from existing public-sector procurement policies designed to purchase wood products that are legally produced and from sustainably managed forests. In general they have two components – requirements for minimum levels of greenhouse gas savings compared to fossil fuels, and requirements (often called ‘land criteria’) relating to the legality and sustainability of forest management. Sometimes other criteria, such as restrictions on types of feedstock or on minimum plant energy efficiency levels, are also included.
Belgium
Energy policy in Belgium is devolved to the country’s three regions: Brussels, Flanders and Wallonia. All three require electricity suppliers to supply a prescribed proportion of renewable energy, underpinned by a system of tradable green certificates, though the three systems are not fully compatible with each other.
In Flanders, the value of a certificate for bioenergy is calculated according to its life-cycle energy balance, whereas in Brussels and Wallonia, eligibility to green certificates depends on the greenhouse gas saving compared to the best available natural gas system. In all cases, however, changes in the forest carbon stock are ignored (i.e. the combustion of biomass is assumed to be zero-carbon); only emissions from production, processing and transport are taken into account.
In addition, in Flanders biomass streams suitable for other uses – e.g. wood that could be used by the pulp and paper or wood-processing industries, except for bark, sawdust, fine pruning wood with a diameter less than 4 cm, twigs of tree crowns with a diameter less than 4 cm, and stumps up to 30 cm above the ground – are not entitled to receive green certificates. To determine whether specific products may be used for bioenergy, the Flemish Energy Agency seeks consent from the Public Waste Agency of Flanders and the federations of the paper and wood-using industries. (Fearing competition for raw materials, Belgium’s paper and wood-processing industries have been generally hostile to the expansion of the biomass energy sector). A more comprehensive set of criteria is being developed.
Wallonia requires feedstock to be ‘sustainable’, i.e. the use of the resource must not compromise its use by future generations. This is subject to audit.
Denmark
In Denmark, woody biomass for energy is included in the government’s timber-procurement policy, most recently revised in 2014, although its application to bioenergy is voluntary throughout the public sector. The policy sets out detailed definitions of ‘legal’ and ‘sustainable’ (very similar to those in the British and Luxembourg policies). Products certified under the two main international forest certification schemes – those of the Forest Stewardship Council (FSC) and Programme for the Endorsement of Forest Certification (PEFC) – satisfy the criteria. These schemes aim to ensure that the ways in which forests are managed and harvested meet criteria for legality and sustainability, but they do not include any criteria – such as greenhouse gas savings relative to fossil fuels – relating to the use of the products for energy.
In 2015, in response to a request from the government, the Danish District Heating Association and the Danish Energy Association introduced a voluntary sustainability standard for biomass.149 This includes similar requirements for legality and sustainability as the government’s procurement policy, and products certified under the FSC, PEFC or Sustainable Biomass Partnership (see below) schemes are considered to meet them. The standard also requires greenhouse gas reduction levels of 70 per cent by 2015, 72 per cent by 2020 and 75 per cent by 2025, compared to fossil-fuel reference levels according to the Renewable Energy Directive methodology. This does not include emissions from changes in forest carbon stock or indirect land use change, though the industry is working to develop further criteria to cover these. The standard also aims not to use biomass where there is regionally competing demand for high-value wood resources or if the supply of those resources derives from deforestation or inappropriate conversion of forest to agriculture.
As noted, application of the standard is voluntary (and only applies to stations with capacity above 20 MW), but the associations aim to increase the level of compliance with the requirements of CHP installations (the only large-scale consumers of biomass for energy in Denmark) from 40 per cent in 2016 to 100 per cent in 2019. The standard will be reviewed in 2018.
The Netherlands
The framework for the Netherlands’ renewable energy policy was set in 2013, when government, industry, unions and NGOs negotiated the Energy Agreement for Sustainable Growth, setting out the means of reaching the country’s targets for renewable energy.150 This included an upper limit of 25 PJ on energy production from biomass co-firing, and the application of sustainability criteria to co-fired biomass.
The criteria were to be negotiated by the energy sector and environmental organizations, and a first draft was published in 2015. The criteria, which apply to industrial boiler steam production from wood pellets as well as to biomass used in co-firing (though only to larger plants – dedicated biomass above 10 MW and, for co-firing, coal stations above 100 MW), include the following:151
- A minimum average reduction of 70 per cent of greenhouse gas emissions compared to fossil fuels, calculated according to the Renewable Energy Directive methodology. While this does not account for any changes in forest carbon stock, evidence must be provided to show that the forest is managed ‘with the aim of retaining or increasing carbon stocks in the medium or long term’ and with a low risk of indirect land use change.
- Restrictions on the types of feedstock: stumps are not allowed, but tops, branches, residues and roundwood are permitted, as long as on average less than half the volume of the annual roundwood harvest from the forest is processed as biomass for energy. In addition, wastes, such as mill residues or post-consumer wood waste, are permitted.
- The exclusion of biomass sourced from high-conservation-value or converted forest land or peatland or where soil and water quality have not been maintained.
- Requirements for sustainable forest management, mainly taken from the country’s timber-procurement policy, including the maintenance and enhancement of biodiversity and the health and production capacity of the forest and its contribution to the local economy.
A detailed system for the verification of compliance with these criteria, including elements that must be included in the sustainable forest-management system and a chain of custody system, is still under development and should be finalized in 2017.152 The Dutch system has the most detailed of all the national sustainability criteria, and some doubt has been expressed that the requirements can actually be satisfied in practice.153
The UK
Since 2015 the UK has applied sustainability criteria for solid biomass under its three main support programmes for renewable energy: for electricity, the Renewables Obligation and the Contracts for Difference system that is now replacing it, and for heat the Renewable Heat Incentive.
There are two sets of criteria. The greenhouse gas criteria, which aim to account for the life-cycle greenhouse gas emissions of the biomass, include targets for emissions per unit of electricity: a minimum of 60 per cent emissions saving by 2017, compared to the 1990 level, increasing to 75 per cent savings by 2025. This is calculated according to the Renewable Energy Directive methodology, which excludes changes in forest carbon stock (apart from direct land-use change) and emissions from indirect land-use change.
The land criteria focus on the land from which the biomass is sourced. These requirements are built on the environmental and social criteria for legal and sustainable forest products contained in the government’s timber procurement policy. FSC and PEFC-certified products satisfy the criteria in this respect, but since much of the biomass sourced from the US is not certified (the uptake of forest certification schemes in the US is relatively low), the regulations also allow operators to supply credible evidence of a low risk of non-compliance against all the criteria for a defined region (an area across which relevant legislation is the same, e.g. a US state) or a smaller area if they can trace it back.154 As in the timber-procurement policy, up to 30 per cent of the biomass used in a facility can be non-compliant with the sustainability requirements (though it must be legal).
In addition, in 2013, the UK announced a cap on approvals for new dedicated biomass plants in the face of a steep increase in the number of applications. No contracts for biomass power were awarded under the first auction for the new Contracts for Difference in February 2015. The next round, which is scheduled to begin in April 2017, will be open to bids for dedicated biomass with CHP. Three contracts have been awarded without auction, however: to Drax for the conversion of its third unit and to two other power stations, one a coal-to-biomass conversion and one a new dedicated biomass CHP plant.
Other government standards
No other national biomass sustainability standards have been developed. In many cases countries regulate domestically produced biomass for energy in accordance with their own national regulations for forestry or agriculture – and sometimes apply their timber-procurement policies – but these do not include carbon-saving requirements.
In the US, the state of Massachusetts introduced sustainability criteria in 2012. Biomass will only be eligible for subsidies under the state’s Renewable Portfolio Standard if it is an eligible fuel – which includes predominantly timber harvest residues, including tops and branches, rather than whole trees – and as long as sufficient woody material is left on the forest floor to replenish soil nutrients and protect wildlife. In addition, biomass plants must demonstrate emissions reductions of at least 50 per cent over 20 years on the basis of life-cycle emissions analyses, including a carbon debt emissions factor, and must satisfy a minimum efficiency level.
Voluntary certification schemes
Voluntary forest certification systems – of which FSC and PEFC are the main global schemes – have come to act as the principal means of proving compliance with many governments’ timber-procurement policies and are often used as proof of meeting some of the biomass sustainability criteria described above. These schemes do not yet contain criteria for greenhouse gas emissions and carbon stocks, however, although this possibility is under discussion. Some biomass and biomass energy companies are certified under one or both of these schemes.
Other schemes have been developed with the aim of including climate impacts alongside other criteria. The Green Gold Label standard, for example, builds on other certification systems in aiming to cover the production, processing, transport and final energy transformation of biomass.155 Founded in 2002 and certifying biomass for the production of bio-based chemicals and other products as well as for energy, it has limited coverage: by November 2016, just 14 companies had been certified, six in the US, three in Canada and five in the EU.
The Sustainable Biomass Partnership
The main biomass certification scheme that has emerged so far is that of the Sustainable Biomass Partnership (SBP), established in 2013 by seven major European utility companies using biomass with the aim of influencing and meeting EU and member-state sustainability criteria for biomass for energy.156 This built on the criteria included in several national timber-procurement policies and biomass sustainability requirements; some of the companies were also developing their own codes of practice for sustainable sourcing.157
The SBP standard includes the following principles and criteria:158
- Definition of the supply base to ensure feedstock can be traced back to its source area.
- Compliance with all relevant laws, including traditional and civil rights, drawing on criteria in the UK’s timber-procurement policy.
- Sustainable management of the forest and forest operations, and protection for labour and community rights, again drawing mainly on the UK’s timber-procurement policy.
- ‘Regional carbon stocks are maintained or increased over the medium to long term’ (principle 2.9). This includes not sourcing feedstock from areas that had high carbon stocks in January 2008 and no longer have them, and sourcing only ‘where analysis demonstrates that feedstock harvesting does not diminish the capability of the forest to act as an effective sink or store of carbon over the long term’.
- No use of genetically modified trees.
The SBP standard includes a calculation of the energy and carbon balance of the biomass used for energy, to be carried out by the end user using data from the supplier.159 While this includes a requirement to record the type of feedstock (primary feedstock from forests (products or residues), woody energy crops, wood industry residues or post-consumer wood; and classification by physical form: sawdust, woodchips, roundwood, wood logs, bark, etc.) and detailed calculations of the energy used in the supply chain (harvesting, production, transport and storage), it does not include a calculation of any change in forest carbon stock.
The SBP does not set precisely what evidence must be provided to demonstrate compliance with each indicator on the grounds that this will vary among different operations, though it does include examples for each of its criteria. Verification involves a regional risk-based approach, based on a desk-based assessment against the criteria leading to a risk rating for each indicator. Where risks are identified, appropriate mitigation measures must be defined, implemented and monitored.
Risk assessments for Estonia, Latvia and Lithuania were published in 2015. Operations in all three countries were found to have a low risk of non-compliance, with risks identified with just three out of 38 criteria: possessing procedures to address potential threats to high-conservation-value areas (all three countries were found to be at risk), possessing procedures for identifying high-conservation-value areas (Latvia) and means to ensure the protection of forest workers’ health and safety (Latvia and Lithuania).
No figures are yet available on the extent of the biomass energy supply chain covered by SBP certification, but given that the system was set up by several major European energy companies, it has significant potential at least in the European market. The British and Danish authorities have confirmed that SBP certification meets the requirements of their national criteria. As of the autumn of 2016, six bodies had been accredited to carry out certification against the SBP standard, and certificates had been issued to over 60 organizations.160 This did not include Enviva, the pellet company most commonly associated with accusations from NGOs of unsustainable practices.
Conclusions and recommendations
In principle, applying sustainability criteria to the provision of regulatory and financial support to biomass energy is a potential way of tackling the problems discussed in Chapter 1, and of restricting support to those uses with zero or low carbon payback periods as well as to those where the feedstock originates from legally and sustainably managed forests.
However, the existing schemes in EU member states, the draft criteria included in the proposed new Renewable Energy Directive and the voluntary certification schemes now developing, including that of the Sustainability Biomass Partnership, are not satisfactory. Most importantly, they fail to account, comprehensively or at all, for changes in forest carbon stock (apart from direct land-use change), which, as discussed in Chapter 1, is a crucial element in determining climate impacts. Effectively, these criteria permit the provision of financial and regulatory support to policy options that could increase carbon emissions in the short, medium and possibly long term.
The requirements in the Dutch criteria that the forest is managed ‘with the aim of retaining or increasing carbon stocks in the medium or long term’, and in the SBP’s standard that ‘regional carbon stocks are maintained or increased over the medium to long term’ are too vague. Forest carbon stock levels may stay the same or increase for reasons entirely unconnected with use for energy; the important issue is what levels they would have reached in the absence of biomass energy use. In addition, as discussed in Chapter 1, from the point of view of mitigating climate change, there is a major difference between the medium term and the long term; arguably, anything longer than the short term is too long.
The inclusion in the draft new Renewable Energy Directive of a requirement for the country from which the forest biomass is sourced to be a party to the Paris Agreement that accounts for changes in carbon stock associated with biomass harvests is a step in the right direction, ensuring that the emissions resulting from the biomass use count against climate targets. However, the phrase ‘accounted towards the country’s climate commitments’ needs to be carefully defined. As explained in Chapter 2, the choice of forest baseline against which countries account can mean that some biomass-related emissions effectively go unaccounted for. In addition, as discussed in Chapter 1, the full climate impact of the use of forest residues may be significantly underestimated in current models, given its potential effects on soil carbon levels and tree growth rates. If a country is not a party to the Paris Agreement or does not account for biomass-related carbon stock changes, the draft criteria specify that laws must be in place in the country of origin to ‘conserve and enhance carbon stocks and sinks’. This begs the same kind of questions as the terminology used in the Dutch and SBP criteria discussed above, and is equally unsatisfactory.
Robust sustainability criteria must deal with the impact on greenhouse gas emissions as well as the legality and sustainability of forest management. One option would be for the greenhouse gas element to be underpinned by a comprehensive life-cycle analysis for each type of feedstock, including changes in the forest carbon stock alongside supply-chain emissions associated with harvesting, processing and transport (including methane emissions from storage, as discussed in Chapter 1). This is not a straightforward process – varying with the type of tree species, the location of the forest, the characteristics of the technology involved, transport distances and so on – but the UK’s BEaC calculator, among other means of estimating payback periods, provides a potential methodology. A similar approach could be applied to calculate default values for different biomass feedstocks (the draft Renewable Energy Directive contains default values, but only taking into account supply-chain emissions). However, as discussed in Chapter 1, the impact of biomass energy use also depends on the counterfactual: what would have happened to the wood, and the forest from which it was sourced, if it had not been used for energy? Since this is not a fixed element, it is virtually impossible for sustainability criteria to incorporate it.
A more practical approach would be to limit the types of feedstock that can be used, as several EU member states and the US state of Massachusetts already do. The aim would be to restrict eligibility for support to those feedstocks that are most likely to reduce net carbon emissions (or have low carbon payback periods): primarily mill residues, together with post-consumer waste. Fast-decaying forest residues could also fit into this category, but in practice this is small-diameter material that is likely to contain too much moisture and dirt to render it usable by biomass plants; and it would be very difficult for policy to distinguish easily between fast and slow-decaying residues.
An additional element could be a requirement for a minimum level of efficiency of the plant in which the biomass is burnt (again, as in a number of EU member states and, for new installations, in the draft Renewable Energy Directive), maximizing the energy delivered per unit of carbon emitted. In practice, this should restrict financial and regulatory support for biomass use to combined heat and power installations.
Even when restricted in this way, policies should ensure that subsidies do not encourage the biomass industry to divert raw material (such as mill residues) away from alternative uses (such as fibreboard), which have far lower impacts on carbon emissions. This may require the sustainability criteria to be adjusted from time to time depending on market conditions. The cascading principle included in the EU Forest Strategy, in which combustion for energy is the last use of wood after a series of other uses, is a good one and it is regrettable that it is not reflected in the new draft Renewable Energy Directive.
Alongside these emissions criteria, land criteria – applying the same kind of requirements for legal and sustainable sourcing already found in many timber-procurement policies and the FSC and PEFC – play an important role in protecting the way in which the forests are managed. Most national and voluntary sustainability criteria already contain these kind of requirements, but they face a problem in sourcing from areas such as the US southeast, where the uptake of forest certification is very low and most forests are largely unregulated. It remains to be seen whether the risk-based approach found in the UK requirements, the SBP standard and the draft Renewable Energy Directive can deliver products that reliably meet the criteria. Desk-based assessments should be supplemented by on-the-ground inspections, ensuring, for example, that support is not given where whole trees are used, and in particular where old-growth forests are being logged for energy or converted to plantations.
132 See Toop, G. (2013), ‘Overview of EU criteria and national initiatives’, www.danskelbil.dk/~/media/Biomasse/Praesentationer/6Ecofys_GemmaToop.ashx (accessed 29 Dec. 2016).
133 European Commission (2010), Report from the Commission to the Council and the European Parliament on sustainability requirements for the use of solid and gaseous biomass sources in electricity, heating and cooling, Brussels: European Commission, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52010DC0011&from=EN (accessed 29 Dec. 2016).
134 Pelkmans, L. et al. (2012), Benchmarking biomass sustainability criteria for energy purposes, Mol: Belgium, https://ec.europa.eu/energy/sites/ener/files/documents/2014_05_biobench_report.pdf (accessed 29 Dec. 2016).
135 European Commission (2014), State of play on the sustainability of solid and gaseous biomass used for electricity, heating and cooling in the EU, Brussels: European Commission, p. 17 http://ec.europa.eu/energy/sites/ener/files/2014_biomass_state_of_play_.pdf (accessed 29 Dec. 2016).
136 European Commission (2014), A Policy Framework for Climate and Energy in the Period from 2020 to 2030, Brussels: European Commission, p. 7, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52014DC0015&from=EN, (accessed 29 Dec. 2016).
137 European Commission (2013), A New EU Forest Strategy: for forests and the forest-based sector. Brussels: European Commission, pp. 4–5, http://eur-lex.europa.eu/resource.html?uri=cellar:21b27c38-21fb-11e3-8d1c-01aa75ed71a1.0022.01/DOC_1&format=PDF (accessed 29 Dec. 2016).
138 European Commission (2016), Proposal for a Directive of the European Parliament and of the Council on the promotion of the use of energy from renewable sources (recast), Brussels: European Commission, Article 26, https://ec.europa.eu/energy/sites/ener/files/documents/1_en_act_part1_v7_1.pdf (accessed 29 Dec. 2016).
139 European Commission (2016), Impact Assessment: Sustainability of Bioenergy, Accompanying the document Proposal for a Directive of the European Parliament and of the Council on the promotion of the use of energy from renewable sources (recast), Brussels: European Commission, p. 16, http://eur-lex.europa.eu/resource.html?uri=cellar:1bdc63bd-b7e9-11e6-9e3c-01aa75ed71a1.0001.02/DOC_1&format=PDF (accessed 29 Dec. 2016).
140 Ibid.
141 Ibid., p. 31.
142 Ibid., p. 37.
143 The impact assessment modelled the impacts of four options for constraints on biomass use. Although it did not choose between them, Option 3 is nearest to the proposals contained in the draft directive. For this option, projected cumulative changes in net greenhouse gas emissions are -8 to -34 MtCO2-eq (-0.04 to -0.20 per cent) over 2021–30 and -10 to +17 MtCO2-eq (-0.03 to +0.05 per cent) over the period 2031–50. Ibid., p. 47.
144 Ibid., p. 126.
145 Ibid.
146 Ibid., p. 37.
147 Except where noted, information taken from Pelkmans, L. et al. (2012), Benchmarking biomass sustainability criteria for energy purposes; Toop, G. (2013), ‘Overview of EU criteria and national initiatives’; Junginger, M. (2015) ‘Sustainability regulation for solid biomass for energy in NL, BE & UK’, presentation to Conference on Biomass and Sustainability, Copernicus Institute, Utrecht University 19 October 2015, Copenhagen; and Richter, K. (2016), A Comparison of National Sustainability Schemes for Solid Biomass in the EU, Fern, http://www.fern.org/sites/fern.org/files/comparison%20of%20national%20sustainability%20schemes.pdf (accessed 30 Dec. 2016).
149 Dansk Energi and Danske Fjernvarme (2015), ‘Industry agreement to ensure sustainable biomass (wood pellets and wood chips)’, www.danskenergi.dk/~/media/Biomasse/IndustryAgreement_Biomass-20150909.ashx (accessed 29 Dec. 2016).
150 Energie Akoord and Sociaal-Economische Raad (2013), The Agreement on Energy for Sustainable Growth: A Policy in Practice, http://www.energieakkoordser.nl/doen/engels.aspx (accessed 29 Dec. 2016).
151 Netherlands Enterprise Agency (2016), SDE+ sustainability requirements for solid biomass, http://english.rvo.nl/sites/default/files/2016/03/SDE%20Sustainability%20requirements%20for%20solid%20biomass.pdf (accessed 29 Dec. 2016).
152 For an outline of the proposals and responses to a public consultation on them, see Netherlands Enterprise Agency (2016), Report on the consultation of the draft verification protocol ‘Sustainability solid biomass’, http://english.rvo.nl/sites/default/files/2016/07/Report-on-the-consultation-of-the-draft-verification-protocol-sustainability-solid-biomass-June-2016.pdf (accessed 29 Dec. 2016).
153 Griffiths, J. (2016), ‘Background Paper for Scoping Dialogue on Sustainable Woody Biomass for Energy’, p. 10.
154 See UK Department of Energy and Climate Change (2014), Risk Based Regional Assessment: A Checklist Approach, London: UK Department of Energy and Climate Change, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/390148/141222_Risk_Based_Regional_Assessment_-_A_Checklist_Approach_-_Guidance_final.pdf (accessed 30 Dec. 2016).
155 See the Green Gold Label website, http://www.greengoldcertified.org.
156 See the Sustainable Biomass Partnership website, http://www.sustainablebiomasspartnership.org.
157 See, for example, DONG Energy (2014), DONG Energy Programme For Sustainable Biomass Sourcing, http://assets.dongenergy.com/DONGEnergyDocuments/com/Responsibility/Documents/2014/DONG_Energys_Programme_for_Sustainable_Biomass_Sourcing_EN.pdf?WT.mc_id=sustainable_biomass_sourcing_2015 (accessed 30 Dec. 2016).
158 Sustainable Biomass Partnership (2015), SBP Framework Standard 1: Feedstock Compliance Standard, http://www.sustainablebiomasspartnership.org/docs/2015-03/sbp-standard-1-feedstock-compliance-standard-v1-0.pdf (accessed 30 Dec. 2016).
159 Sustainable Biomass Partnership (2016), SBP Instruction Document 5B: Energy and GHG Data, Version 1.1, http://www.sustainablebiomasspartnership.org/docs/Instruction-Document-5B-Energy-and-GHG-Data-v1-1-Oct16.pdf (accessed 30 Dec. 2016).
160 See the section on ‘Approvals and Certifications’ on the Sustainable Biomass Partnership website, http://www.sustainablebiomasspartnership.org/approvals-and-certifications.