Biofuels and biomass Sustainability Schemes must be re-approved by June 2021 to show that they are in compliance with the new Renewable Energy Directive (RED II). The process is already underway and Schemes are invited to submit their updated documents for scrutiny. But there is the potential for further changes. Not all the rules are set in stone, so there is still time for companies to influence important decisions, or even change to a different Scheme before June of next year.
History says that not all approved Schemes will apply promptly and some may decide not to reapply at all, leaving certificate holders stranded. Operators who are with one of the smaller schemes, or one that has priorities other than bioenergy, should start asking questions. Organisations that are with Schemes that specialise in bioenergy, 2BS, ISCC, or REDcert, can rest assured that they were on time for the last reapproval process, hence they will be so on this occasion.
RED II brings in a number of changes for biofuels companies and completely new requirements for suppliers of biomass for heating, cooling and power generation. And there is flexibility around how Schemes will translate the RED II text into requirements for certificate holders. To gain an understanding of the process, go to the ‘assessment protocol’. This is the document that shows how the Schemes will be assessed by the European Commission for compliance with each individual requirement of RED II. It is essential reading.
Some changes emerge clearly from the assessment protocol. Oversight of waste biofuels supply chains will increase, with audits for smaller sites where waste originates. Operators will have to declare what state support they are receiving for each consignment of product and they will have to take part in the Europe wide tracking database when it is ready. Soil quality must be maintained when agricultural waste is removed from the field and used for biofuel or biogas. However other aspects still require clarification, which is discussed further below.
Forest biomass suppliers will be subject to the most changes. For the first time, they will have to take steps to ensure that production is sustainable and meets UN reporting requirements covering emissions and removals of carbon from forestry. Of course they may be doing this already, but the auditor will now require formal evidence. This can be provided at a country or certified operator level. Schemes will have an important role to play in advising forest managers whether their countries comply with RED II, which will smooth the path to compliance. Operators in those countries that do not fulfil requirements will look to their Voluntary Scheme to provide the framework for certified sustainable production with maintenance of carbon stocks and sinks at the local level.
There are still a number of decisions to be taken which will have implications for biofuels producers. With the emergence of more categories of biofuels, questions are being asked about the extent they can be mixed and mass balanced together. There will be advanced, double counting, waste derived and conventional biofuels from food and feed crops, with the additional possibility of recycled carbon fuels. They will all count to differing extents towards targets for renewable energy. The assessment protocol warns that mass balance systems must not increase the risk that rules for determining the contribution of biofuels towards the targets for renewable energy are ‘not correctly applied or circumvented’. Mixing biofuels that are chemically identical but have a different sustainability status could increase that risk. Guidance and rules will be published later but now is the time to put forward arguments that could influence the decision making process.
For the first time there will be a RED compliant certification for low indirect land-use change risk raw materials produced by increasing yields, sequential cropping or from degraded/unused land. Low ILUC risk fuels will be complicated to certify but they will have advantages in the market place into the future. More detail has recently been presented so operators should be able to get to grips with the likely criteria for low ILUC risk certification whilst there is still time to input into the discussion.
So as bioenergy Sustainability Schemes adapt their rules and requirements in preparation for the upcoming changes, companies should dig deeper into the detail, or risk finding themselves short-changed when it’s all over.
Published: 27 November 20