In the midst of the debate over the whether importing wood pellets to the European Union from the southern United States is a sustainable undertaking for electricity generators there, the Sustainable Biomass Partnership (SBP) has released its Biomass Assurance Framework. As part of the framework, Standard #1: Feedstock Compliance Standard outlines a set of criteria for demonstrating that pellets consumed in the EU are sustainably sourced. Based in part on standards put in place by the UK Department of Energy and Climate Change (DECC) and current forest certification schemes, the standard outlines ten areas for assessment.
While most of these criteria (2.1, 2.2, 2.4-2-8) are provable using local, state and federal laws and best management practices, all of which are relatively standard in the southern US, Criterion 2.3 will require the use of additional data about forest inventory and growth-to-drain profiles.
To “ensure productivity is maintained,” the SBP specifies the following:
On its face, this guidance makes sense. Forest2Market has been using inventory, growth and harvest data to measure the feedstock sustainability for its customers since its inception.
Because of this experience, we can foresee several issues that may arise as auditors attempt to verify compliance with this criterion.
1. What parameters will be used to determine whether productivity levels are sustainable? Unlike the static view provided by forest inventory, growth-to-drain ratios demonstrate the trajectory of forest inventory. A ratio of growth to drain – the biological increase in inventory compared to harvests – measures the balance between supply and demand. At Forest2Market, we use the following parameters when determining sustainability of supply. Will these parameters be acceptable, or will some buffer be needed?
2. Will growth-to-drain ratios for the year the biomass was harvested be sufficient for proving sustainability? Does the use of “long-term production capacity” mean that a forecast of growth-to-drain ratios will be required? If so, how long is “long-term?”
3. If long-term production capacity requires a forecast, what happens if the growth-to-drain ratio falls below equilibrium for one or two years of the forecast but then recovers thereafter? We often run into this situation in our sustainability work. Clearly, a set of parameters will be needed to ensure consistency among auditors.
4. Will long-term production capacity apply to all product classes or just those being used by the pellet manufacturer to produce the pellets? There can be significant differences in the growth-to-drain ratios for products, as this table shows. Will facilities using Plantation Hardwood (with a drain of nearly double growth) or Natural Hardwood (with growth of 2.5 times drain) be required to report a growth to drain ratio of 1.63?
5. What if a facility cannot demonstrate compliance for reasons other than its own demand? Will it be able to offer evidence that a negative growth-to-drain ratio was caused by factors other than its own consumption of biomass?
One recent example of this occurred as a result of the Great Recession in the United States. As many landowners delayed pine sawtimber harvests during the housing crisis, regular replantings were also delayed. This created an age class gap for the years when pulpwood—had it been replanted on schedule—would have been thinned to make room for sawtimber to grow. Sawtimber harvests are once again picking up steam. And as they do, replantings will follow, and the cycle will reverse itself in a short span of time. Gaps like these are natural reactions to the market; they are not harbingers of deforestation or evidence of a lack of sustainability.
The SBP has indicated that the framework they describe “is adaptive in its approach and will evolve through a process of continuous improvement enabling future regulatory requirements to be incorporated as necessary.” To that end, the SBP will continue to offer clarifications and corrections to the standards as part of the implementation process. Answering these five questions will help ensure that auditors are applying a consistent methodology for determining compliance with this criterion as the framework becomes the industry standard for demonstrating biomass sustainability.