As part of its combined energy and climate change policies, the UK has developed biomass sustainability criteria to ensure that the biomass it uses is "sustainable, delivers real carbon savings and protects valuable habitats at home and abroad." On September 7, the Department of Energy and Climate Change (DECC) took measures to strengthen its biomass sustainability criteria. The criteria, as proposed by DECC, would place limits on lifecycle emissions, set requirements for forest sustainability and restrict the amount of biomass power that can be eligible for renewable obligations certificates (ROCs).
Greenhouse Gas Emissions Criteria
The maximum amount of GHG that can be emitted throughout the supply chain—from the forest to the power facility—is proposed at 285.12 kgCO2eq/MWh of electricity through April 2020. For new dedicated biomass power facilities accredited after April 2013, which are designed to be both more clean and efficient, that number will be 240 kgCO2eq/MWh. Between 2020 and 2025, the threshold will be lowered to 200 kgCO2eq/MWh for dedicated biomass plants and 240 kgCO2eq/MWh for plants converted from coal to biomass or co-firing.
Currently, the UK sets general restrictions for materials sourced from land with high biodiversity value or high carbon stock – including primary forest, peatland, and wetlands. This approach has proven untenable over the last two years, however, as there has been some disagreement over definitions and because current forest certification schemes alone are not sufficient to meet the criteria.
In its stead, DECC proposes replacing this requirement with the UK’s public procurement policy for wood. Under the new policy, a biomass power facility would have to demonstrate that 70 percent of the wood used to manufacture the pellets it procures has chain of custody certification, from the forest of origin to the final user.
In order to demonstrate compliance, a supplier must provide independent chain of custody certification of the timber or timber products by one of the major certification schemes (SFI, ATFS, CSA, FSC). In the US, especially in the South where the majority of industrial pellet mills are or will be located, widespread certification of this type is not common. As mills purchase wood from dozens of different dealers, brokers or loggers who buy the timber from hundreds of landowners, the scope of any project to increase certification will require significant resources.
If the wood does not have chain of custody certification by one of these schemes, the supplier may show chain of custody compliance with alternative documentation. The documents that outline the evidence required can be found at the UK’s Central Point of Expertise on Timber Procurement.
These proposed changes will require the development of a track and trace system for wood, where an independent third-party can identify that a particular load of biomass delivered to a pellet mill comes from a tract or tracts that are managed sustainably and that the biomass was harvested and delivered to the mill in a way that complied with all harvest guidelines and laws. While it is possible to develop this type of system, it may not be possible to do so by April 2013, when these changes are due to take effect. The comment period for these proposed changes are due November 30, 2012.
Dedicated Biomass Cap
DECC also proposes to cap the amount of a supplier’s obligation that can be met with new dedicated biomass. The proposed limit is 19 percent in 2013/2014, 17 percent in 2014/2015, 15 percent in 2015/2016 and 12 percent in 2016/2017. The comment period for the cap runs through October 19.