TODAY’S STUDY: SUSTAINABILITY OF BIOFUELS IN EUROPE Searching For Sustainability; Comparative Analysis of Certification Schemes for Biomass used for the Production of Biofuels
Inga Schlamann, Barbara Wieler, Martina Fleckenstein, Jenny Walther-Tho, Nina Haase, Laszlo Mathe, November 13, 2013 (World Wildlife Fund Deutschland)
Executive Summary This study analyses and compares all stand- ards and certification schemes for biofuels production that were approved to comply with the EU RED requirements. The study compared all of the EU-recognized schemes for certifying the sus- tainability of biofuels which had been established as of June, 2013. Measuring these 13 standards and certification schemes against WWF’s sustainability criteria revealed each standard’s overall added sustainability value and identified areas for improvement. The results of this study are an overview and comparison of strengths and weaknesses for each standard from which the authors extracted recommendations for the scheme owners for improvement of their environmental and social performance. The study follows on with recommendations for EU RED legislation.
Aim of the study
1. Identify strength and weaknesses of the analyses standards.
2. Give recommendations to standard owners for improvments.
3. Provide guidance to economic operators and regulators regarding the quality of RED requirements.
4. Offer recommendations for the revision of EU RED and the approval process of schemes under EU RED.
The European Union (EU) promotes the use of biofuels as an alternative re- newable energy source to replace fossil fuels and mitigate climate change. The European Parliament’s 2009 Renewable Energy Directive (RED) and the Fuel Quality Directive (FQD), mention biofuels as the most effective way to achieve a low-carbon transport sector.
By 2020, 20 per cent of the energy used in the EU and 10 per cent of the energy used by each member state in the transport sector must come from renewable sources. The available arable land in the EU is insufficient to grow the raw materials and feedstock needed to produce biofuels in the medium and long term. Therefore a part of the biomass production has to be cultivated outside of the EU. Biofuels and bioliquids used in the EU must meet EU RED sustainability criteria in order to be eligible for funding or to count them towards national targets. These criteria apply regardless of the origin of the biofuels and bioliquids. The applicable mandatory sustainability criteria are specified in Directives 2009/28/ EC and 2009/30/EC.
The Directive lists the following options for implementation: National regula- tions of the member states, private-sector certification schemes, and bilateral agreements. The EC initially decided that the sustainability certification has to be undertaken via private-sector certification schemes. The certification scheme can be recognized and approved by the EU (for globally applicable schemes) or at member state level (for national schemes). As of June 2013, the European Commission (EC) had recognized 13 certification schemes for biofuels.
This desk study examines the written documents of 13 certification schemes for biofuels, which have been recognized by the EC. It was conducted by using the “Certification Assessment Tool” (CAT Version 2.1) developed by WWF. The CAT is a structured way to evaluate and compare voluntary standards and certifica- tion schemes. The tool asks questions and has a scoring methodology to assess the strategic, governance, structural, social, and environmental strengths and weaknesses of standards and certification schemes.
Information sources used were current standard documents as well as publicly available information provided by the EC, or accessible via standard organiza- tions’ homepages and other relevant external organizations’ websites. Interviews with representatives of each standard organization were conducted to verify data. In a last step, comments received from the scheme representatives were integrated and assessments were finalised. The CAT is a desk-based exercise that is based on criteria and processes defined in a scheme’s documentation. As such the CAT assessments contained in this study do not evaluate how a given scheme’s requirements are implemented in practice.
All of the analysed standards implement the mandatory minimum requirements specified in EU RED.
Yet many of the analysed standards performed on a middle or low level against WWF criteria for a credible sustainable environmental and social standard. While the approved standards have very diverse performance with respect to environmental and social criteria, the study shows that multi-stakeholder schemes cover more comprehensively ecological and social requirements.
While most of the current biofuel production debates in Brussels focus on indirect effects, it is important to note that direct effects are not yet adequately addressed in EU RED criteria and/or require further definitions. For example, EU RED does not include mandatory requirements on maintaining and improv- ing soil, water and air quality or consider social issues such as dealing with the affected communities, compliance with the ILO Conventions, and food security.
Based on the analysis, the study produced the following results:
» The requirements of EU RED were implemented to a similar level by all of the recognized standards; however, this does not mean that the standards are sus- tainable according to WWF.
» The current mandatory minimum sustainability requirements prescribed in EU RED cannot ensure that biofuels used in the EU, whether they are pro- duced nationally or are imported, are sustainable according to the key sustain- ability criteria that WWF advocates.
» Multi-stakeholder schemes i.e. those with the active involvement of different stakeholder groups on all levels of the scheme (standard setting, audits and management of the scheme) generally provide a higher level of environmental and social performance. This means that the multi-stakeholder schemes will most likely result in better field-level implementation, as a solid governance structure, transparency and strong audit and accreditation requirements to- gether increase the likelihood of field-level implementation. » Some EU RED standards already go beyond the criteria specified by the EU and address social and deeper environmental issues, including water, soil and air.
» The analysis shows that some important issues are poorly represented in the approved standards, including the implementation of social and environmental management systems on the corporate level, handling of invasive species, limitations on the use of hazardous chemicals, waste and water management, restoration of riparian areas and segregation of supply chains in order to offer a non-GMO option. Many standards do not adequately address transparency in public reporting, internal system governance, and audit scope and intensity.
The results of the analysis and its findings concerning implementation procedures lead to the following policy recommendations.
» As part of the revision of EU RED, requirements that are currently voluntary or are only reporting obligations should now be made mandatory: social aspects, limitations on the use of hazardous chemicals, impact assessment5 and monitoring, mitigation of negative effects for environmental habitats, benefits for surrounding communities, analysis of the impact on food production.
» A significant weak point with respect to implementing the legislation through voluntary standards is inadequate monitoring of the effectiveness of the certification and implementation on site. There is very little documentation on the effectiveness of the standards. From WWF’s viewpoint, the standards employed by the EU for implementing the legislation should provide evidence with regard to the implementation of binding sustainability criteria. Some of the multi-stakeholder standards have various mechanisms in place that should en- sure sound implementation, but most of the standards developed specifically for EU RED lack such checks and procedures.
» While all standards have some form of grievance procedure in place for deal- ing with complaints regarding certification results, the internationally applicable multi-stakeholder schemes with comprehensive criteria have much strong- er grievances processes in place, including for affected communities and other stakeholders.
» There is a gap between requirements and procedures used for sampling and farm inspections, between field audits and desk audits, between regulations for group certification and for the prevalent practices in non-EU countries. Desk audits on the farm level are conducted without consideration of the risk classi- fication, and group certification is granted to completely independent operated farms without strong internal control system (ICS). This jeopardises the inten- tion of EU RED to support environmental and social sustainability through voluntary schemes and should be addressed accordingly during the review of the effectiveness of the standard.
In summary, based on the results of this study, WWF strongly advocates that the EC should include the following points during the review and revision of EU RED:
» The EC should require a multi-stakeholder approach for all approved standards.
» Requirements that are currently defined as voluntary or are only included as reporting obligations should be made mandatory.
» Standards which are recognized within the scope EU RED must be required to use an internationally recognized accreditation body for approving certification bodies6
» Farm audits should generally only comprise on-site audits; remote audits should be not accepted .
» Group certification should be only permitted in a very strictly defined framework (smallholders, cooperatives) together with a required robust internal control system (ICS).
The policy recommendations that go beyond the results of the study address the EC’s recognition and approval process for voluntary standards.
» The recognition and approval process should be more transparent, allow for stakeholder participation and include a grievance mechanism7.
» A monitoring system should be implemented in order to better monitor the effec- tiveness of the certifications, regardless of the scheme.
» The EC should review, on a regular basis, whether the implementation practice of the standard complies with the legislation. The results of the review should be incorporated into the approval process.