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Sustainable Biomass Program

SBP

The Sustainable Biomass Program (SBP) is a certification scheme designed for (solid) woody biomass used in industrial, large-scale energy production.

Lobbying Activity

Response to Protecting biodiversity: nature restoration targets

22 Aug 2022

Introduction SBP is an independent, multi-stakeholder certification scheme designed for solid woody biomass used in large-scale energy production. The SBP certification system provides assurance that solid woody biomass is sourced from legal and sustainable sources and provides verified data along the supply chain to evidence this. SBP-certified biomass accounts for the majority of woody biomass consumed in the EU; in 2021, 82.5% of the industrial pellets consumed in Europe* were SBP-certified. As at the end of July 2022, we had 352 Certificate Holders – Biomass Producers, Traders and End-users – across 34 countries. Through its credible and robust certification scheme, assuring responsible practice throughout the biomass supply chain, SBP is the promise of good biomass and is an integral part of the solution for tackling climate change. Our purpose is to facilitate the economically, environmentally, and socially responsible use of solid woody biomass enabling climate goals to be met and we welcome the recent publication of the proposal for a Regulation on Nature Restoration. Please see attachment for general and specific comments. * Europe refers to Belgium, Denmark, Finland, France (and French territories), Netherlands, Poland, Sweden, United Kingdom and Other EU27.
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Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

6 Jan 2022

SBP supports the proposed amendment to Article 38 of Implementing Regulation (EU) 2018/2066. For the considerations given, including the delayed adoption of the Implementing Acts under Directive (EU) 2018/2001 and the delayed recognition of voluntary schemes, SBP agrees that a one-year presumption of compliance with the RED II sustainability and greenhouse gas emissions saving criteria for biomass used for combustion is appropriate. This will ensure a robust, efficient and harmonised implementation from 1 January 2023.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

25 Oct 2021

Amending Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources: Submission from SBP Introduction SBP is a multi-stakeholder, voluntary certification scheme designed for solid woody biomass used in large-scale energy production. The SBP certification system provides assurance that solid woody biomass is sourced from legal and sustainable sources and provides verified data along the supply chain. Through its credible and robust certification scheme, assuring responsible practice throughout the biomass supply chain, SBP is the promise of good biomass and is an integral part of the solution for tackling climate change. SBP’s purpose is to facilitate the economically, environmentally and socially responsible use of solid woody biomass enabling climate goals to be met. SBP, therefore, has an interest in the amendment of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources. Comments on the proposals SBP is supportive of the European Green Deal (EGD) and the central role for renewable energy. As a renewable energy source, sustainable solid biomass has a recognised contribution to make in the future energy mix as ambitions move towards climate-neutrality. SBP has an important role to play in assuring the legality and sustainability of solid biomass used in energy production and in providing verified data to calculate carbon savings compared to traditional, fossil fuelled energy generation technologies. Below, SBP provides specific comments and suggestions in relation to three aspects of the proposals: • Article 3, paragraph 3 on the cascading principle and exclusion of saw logs and veneer logs; • Article 29(1) (a) and Article 30(6) on installation thresholds; and • Article 29, paragraph 6, first subparagraph, point (a)/point (b), point (iv) on harvesting methods. See attachment.
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Response to Land use, land use change and forestry – review of EU rules

25 Oct 2021

Amending Regulation (EU) 2018/841 and (EU) 2018/1999 – Land use, land use change and forestry: Submission from SBP Introduction SBP is a multi-stakeholder, voluntary certification scheme designed for solid woody biomass used in large-scale energy production. The SBP certification system provides assurance that solid woody biomass is sourced from legal and sustainable sources and provides verified data along the supply chain. Through its credible and robust certification scheme, assuring responsible practice throughout the biomass supply chain, SBP is the promise of good biomass and is an integral part of the solution for tackling climate change. SBP’s purpose is to facilitate the economically, environmentally and socially responsible use of solid woody biomass enabling climate goals to be met. SBP, therefore, has an interest in the amendment of Regulations (EU) 2018/841 and (EU) 2018/1999 and their impact on the land use, forestry and agriculture sector. General comments on the proposals SBP recognises the importance of maintaining and increasing forests in order to achieve climate goals. SBP has considerable experience of best practice, from working with foresters and stakeholders across the wood products industry. Good biomass has a role to play in supporting forests and wood product markets, providing sustainable economic development opportunities as well as providing wider energy systems benefits. Bad biomass practice must be eliminated as it can have detrimental impacts on forest health, on long term sustainability of wood products markets and on achieving climate goals. Sourcing of good biomass can contribute to the development of sustainably managed forests. Good biomass provides economic value to forests, helping to incentivise investment in forests and discouraging land use change. Robust monitoring, reporting and verification, datasets and other emerging forest monitoring technologies are crucial and the Commission should support the development of these. SBP has developed a robust monitoring, reporting and verification system for sourcing biomass and would be pleased to share insights with the Commission to inform this policy development. The role of certification SBP supports the Commission in developing an appropriate mechanism to promote carbon storage in long-lived wood-based materials and products that supports the development of a sustainable bioeconomy. For long-term carbon storage in forests, harvesting of wood, including for bioenergy, is appropriate and certification has a role in ensuring the sustainability of those practices. The SBP certification system has provided, and continues to provide, a practical approach to support the decarbonisation objectives of European policy makers and energy producers. The system facilitates and promotes the trade of legal and sustainable woody biomass across international markets, and importantly enables the calculation of the full energy and carbon footprint of biomass from its origin to its point of end use.  SBP would be pleased to share its experience of developing robust and practical sustainability requirements and operating a certification system. SBP 25 October 2021
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

26 Jul 2021

The Sustainable Biomass Program (SBP) is an independent voluntary certification scheme for (solid) woody biomass used in industrial, large-scale energy production. SBP does not certify other forms of bioenergy, such as agricultural biomass or biofuels. SBP-certified biomass accounts for the majority of imports of woody biomass into the EU. In 2020, 76.8% of the industrial pellets consumed in the EU-28 were SBP-certified. We have over 320 Certificate Holders – Biomass Producers, Traders and End-users – across 31 countries. Our unique online Data Transfer System sets us apart from other certification schemes in the sector. It transfers sustainability and energy data associated with each biomass transaction, allowing greenhouse gas emissions calculations to be made for the entire life cycle of the biomass. International and European climate goals cannot be met without biomass. Our purpose is to facilitate the economically, environmentally and socially responsible management of biomass enabling climate goals to be met. SBP is an internationally recognised solution for Biomass Producers, Traders and End-users to demonstrate compliance with regulatory requirements. Currently, SBP is the only scheme that can be used to demonstrate compliance in the four key biomass markets of geographical Europe (Belgium, Denmark, the Netherlands and the UK). SBP has also applied for recognition under the re-cast EU Renewable Energy Directive (RED II). SBP is pleased to offer feedback on the rules to verify sustainability and greenhouse gas emissions saving criteria and low indirect land-use change-risk criteria, please see attached file.
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

Submission by the Sustainable Biomass Program Introduction The Sustainable Biomass Program (SBP) is an independent voluntary certification scheme for (solid) woody biomass used in industrial, large-scale energy production. SBP does not certify other forms of bioenergy, such as agricultural biomass or biofuels. SBP-certified biomass accounts for the majority of imports of woody biomass into the EU. In 2020, 76.8% of the industrial pellets consumed in the EU-28 were SBP-certified. We have over 320 Certificate Holders – Biomass Producers, Traders and End-users – across 31 countries. Our unique online Data Transfer System sets us apart from other certification schemes in the sector. It transfers sustainability and energy data associated with each biomass transaction, allowing GHG emissions calculations to be made for the entire life cycle of the biomass. International and European climate goals cannot be met without biomass. Our purpose is to facilitate the economically, environmentally and socially responsible management of biomass enabling climate goals to be met. SBP is an internationally recognised solution for Biomass Producers, Traders and End-users to demonstrate compliance with regulatory requirements. Currently, SBP is the only scheme that can be used to demonstrate compliance in the four key biomass markets of geographical Europe (Belgium, Denmark, the Netherlands and the UK). SBP has also applied for recognition under the re-cast EU Renewable Energy Directive (RED II). Feedback SBP is pleased to offer feedback on the Renewable Energy Directive – guidance on the sustainability criteria for forest biomass used in energy production as follows: Article 2 Definitions No definition of “primary forests.“ Article 4, paragraph 1, b, iv Recommend avoiding prescriptive five year limitation as other time periods may be appropriate in specific forest types and eco-regions. Article 4, paragraph 1, b, iv ‘Deadwood’ may be an important attribute of biodiversity values but there are many others. Recommend including ‘deadwood’, inter alia, as an example of desirable attributes. Article 4, paragraph 1, b, iv ‘Vulnerable soils’ is not defined. Recommend removing this term and include under the existing requirement that ‘logging systems minimising impacts on soils …’. Article 4, paragraph 1, b, iv Clear-cuts may be the appropriate silvicultural treatment for some forest types and eco-regions. Suggest avoiding specific reference to clear-cuts and include, inter alia, as an example of management prescriptions. April 2021
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Comments on the EU classification system for green investments Solid woody biomass as part of the energy mix has a significant contribution to make to meeting climate goals both today and in the future. REDII (Directive (EU) 2018/2001) has established sustainability criteria for solid biomass used in energy production. In order to maintain investor confidence and safeguard the contribution of biomass to climate goals, it is essential that there is consistency between the requirements of REDII and the technical screening criteria of the delegated regulation supplementing Regulation (EU) 2020/852. As an over-riding principle, the screening criteria should not contain more stringent requirements than REDII and other relevant legislation. Specifically in the case of REDII, a review has been launched and the delegated regulation should not pre-empt the outcome of that process. For example, a GHG emissions saving threshold of 80% is stated in the delegated regulation, which is consistent with the threshold in REDII for installations commencing operation from 2026, but is at odds with the current REDII threshold of 70%. In general, use of clear terms and definitions that are well understood in the global forest and solid woody biomass industry will ensure that regulatory regimes are workable and the policy intent is met. Layman’s terms can often be misleading, for example, the term ‘whole tree’ is a poor definition. To the lay person, thinnings may be considered to be whole trees, when in reality they are instrumental in delivering the economic, social and environmental benefits of sustainable forest management. Further, there is no clear link between whole trees and either sustainability or carbon benefits. Therefore, SBP would urge that the term ‘whole tree stems’ is removed from the delegated regulation and consistency with REDII upheld. Finally, both in terms of Annex 1 on climate change mitigation and Annex 2 on climate change adaptation, we offer the following comments: • 1.4 Afforestation (4 Guarantee of permanence) references “the area on which the activity takes place” and commitments of “the operator of that activity”. In the case of biomass, the operator of activity can be the biomass producer, that is, the first gathering point. In the biomass supply chain, biomass producers can and already do undertake to deliver activities such as afforestation through, for example, contractual requirements with forest/landowners. Therefore, a landscape/regional forest management plan may be made by the biomass producer covering the forests that it sources from. • 1.4 Afforestation (4 Guarantee of permanence, (6) Protection and restoration of biodiversity and ecosystems (c), (e) and (h)). We fully support the maintenance and protection of biodiversity and ecosystems and it should be recognised that commercial forestry can do both. As written, the text implies that commercial plantations do not count. Commercial forestry is a legitimate activity, especially where wood products are being used to substitute more carbon intensive products. • 1.6 Reforestation (1 Forest management plan or equivalent instrument) references forest level certification. It should be noted that certification can be at the landscape/regional level, it does not have to be solely at the forest level. A landscape/regional approach is consistent with approaches being developed across a number of schemes and initiatives. For example, WWF’s Landscape Sourcing Report: Sustainable Business Using the Landscape Approach makes the case for the private sector to adopt landscape approaches to sustainably strengthen and increase cost effectiveness within their supply chains. Further, REDII permits a regional approach and the same argument as above (first bullet) stands in relation to a landscape/regional forest management plan covering the forest sourcing area.
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Response to EU Forest Strategy

3 Dec 2020

EU Forest Strategy Roadmap: SBP response Introduction SBP is a multi-stakeholder, voluntary certification scheme designed for solid woody biomass used in large-scale energy production. The SBP certification system provides assurance that solid woody biomass is sourced from legal and sustainable sources and provides verified data along the supply chain. Through its credible and robust certification scheme, assuring responsible practice throughout the biomass supply chain, SBP is the promise of good biomass and is an integral part of the solution for tackling climate change. SBP’s purpose is to facilitate the economically, environmentally and socially responsible use of solid woody biomass enabling climate goals to be met. SBP welcomes the opportunity to respond to EU Forest Strategy Roadmap. As a certification scheme for solid woody biomass used in energy production, we aim to safeguard woody biomass production through support for sustainable forest management and forest regeneration. Comments SBP offers the following comments on delivering the desired impacts of the EU Forest Strategy: • The EU Forest Strategy should drive a consistent policy approach to forests across the EU. The characteristics of, and habitats provided by, forests across the EU differ greatly and fulfil multiple functions. SBP believes that a Forest Strategy communicating a few, very clear principles to guide and drive Member States in the right direction will be impactful. • The opportunity for harmonisation of forest policy with the goals and policy frameworks of the New Green Deal, Bioeconomy Strategy, RED II and the Biodiversity Strategy is welcome. The various EU initiatives approach forests and solid woody biomass from different perspectives. However, SBP believes that the policy goals of the Bioeconomy Strategy, REDII and the Biodiversity Strategy and the RED II, for example, maintaining or increasing carbon sinks, would benefit from a consistent approach. • Climate change puts increasing pressure on European forests. SBP supports actions that nurture the forests that we have and plan for the forests of the future. • The EU Forest Strategy should have a neutral approach to the different possibilities of economic utilisation of timber. In supporting and enhancing sustainable forest management practice, the marketing of forest products is very important and should be governed by market forces rather than political will. If there is demand for long-lived wood products, the market will send those signals and the forest manager/land owner will respond accordingly. The same is true of other economic utilisation pathways, such as, bioenergy. Market forces act to secure the needed financial support to manage forests in the correct way. • Afforestation can help to increase carbon sinks and can provide feedstock for different applications in the bioeconomy. Support for afforestation should be evidenced-based to ensure there is a carbon benefit, thereby not contradicting policy goals. • SBP supports the proposal of goals for greater protection of European primary and old-growth forests. Closing Remarks SBP supports an approach that builds on sustainable forest management, secures consistency across Member States in line with EU policy objectives and recognises the value of market forces as drivers for responsible practice.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources: Submission from Sustainable Biomass Program Introduction SBP is a multi-stakeholder, voluntary certification scheme designed for solid woody biomass used in large-scale energy production. The SBP certification system provides assurance that solid woody biomass is sourced from legal and sustainable sources and provides verified data along the supply chain. Through its credible and robust certification scheme, assuring responsible practice throughout the biomass supply chain, SBP is the promise of good biomass and is an integral part of the solution for tackling climate change. SBP’s purpose is to facilitate the economically, environmentally and socially responsible use of solid woody biomass enabling climate goals to be met. SBP, therefore, has an interest in the revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources. Comments on the Inception Impact Assessment SBP is supportive of the European Green Deal (EGD) and the central role for renewable energy. As a renewable energy source, sustainable solid biomass has a recognised contribution to make in the future energy mix as ambitions move towards climate-neutrality. SBP has an important role to play in assuring the sustainability of solid biomass used in energy production and providing data to support carbon savings compared to traditional fossil fuelled energy generation technologies. Option 2 of the Inception Impact Assessment gives information campaigns as an example of a non-regulatory measure to fulfil the objective of the initiative. SBP is supportive of evidence-based information campaigns and believes there is a need for a campaign in support of the use of sustainable biomass for energy. SBP is well-placed to assist in the provision of information to support such a campaign. With over five years’ experience of operating a certification system for solid biomass and with close to 300 Certificate Holders, which collectively accounted for some 12 million tonnes (61% of EU industrial pellet consumption) of woody biomass produced and sold in 2019, SBP is in a position to inform the biomass debate. SBP supports Option 3 to raise the ambition level of the REDII targets in line with the 2030 Climate Target Plan. An increased contribution from renewables, including solid biomass, across all sectors (not just energy) will necessitate the same demand for sustainability. SBP can offer practical guidance on how to ensure policy intent is implementable and impactful. SBP recognises the intent of Option 4 to amend REDII to translate into legal measures the actions proposed in other energy strategies of the EGD. In this context, we believe that harmonisation and a common use of terms and approaches in implementing the requirements across EU legislation and policy frameworks, such as, REDII, Biodiversity Strategy, Forest Strategy, Circular Economy Strategy, Waste and others that are either implemented or under discussion, is needed. For solid biomass, consistent and equivalent criteria across all energy strategies to deliver a harmonised market and a level playing field for all market participants is a necessity. Clear, transparent and well understood definitions are a pre-requisite to support a harmonised market. Again, SBP can offer practical guidance to avoid the risk of unworkable requirements that fail to deliver the policy intent. Closing Remarks SBP supports the overall objective to ensure that renewable energy sufficiently contributes to the achievement of the higher EU climate ambition in line with the ongoing assessment underpinning the Climate Target Plan for 2030. As an independent entity operating a comprehensive certification scheme, SBP is well-placed to offer practical guidance based on experience and understanding of the key issues. SBP 21 September 2020
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Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

11 Oct 2016 · Biomass

Meeting with Shane Sutherland (Cabinet of Commissioner Phil Hogan)

10 Oct 2016 · Biomass

Meeting with Jos Delbeke (Director-General Climate Action)

25 Jan 2016 · Sustainability of biomass

Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development)

8 Jan 2016 · dialogue with the Commission on how biomass can contribute to the ambitious CO2 and renewables targets laid out in the Energy Union plan

Meeting with Dominique Ristori (Director-General Energy) and Ørsted A/S

2 Jul 2015 · Biomass