The reality is that biomass is being used to substitute fossils fuels to meet today’s energy demands
SBP certification scheme: debunking the myths
Carsten Huljus, SBP Chief Executive Officer
7th September, 2016
In a second response to a recent article published in the Ecologist, "Are the UK 'biomass sustainability standards' legitimising forest destruction?", SBP Chief Executive Officer Carstem Huljus debunks the myths in a right of reply
The acceptance of sustainable woody biomass by many European countries as an emerging fuel source for large-scale energy production as part of their package of measures to reduce carbon emissions has been welcomed by some and criticised by others. Energy producers, environmental advocates, policy makers and other stakeholders are engaged in an ongoing dialogue about the pros and cons of biomass as a fuel source to replace fossil fuels.
In the meantime, the reality is that biomass is being used to substitute fossils fuels to meet today's energy demands, and therefore a mechanism for demonstrating compliance with the regulatory, including sustainability, requirements already implemented by some European countries is needed.
Certification schemes offer such a market-based mechanism and are not uncommon; in fact, they have gained in popularity over recent years, particularly in relation to demonstrating the sustainable sourcing and production of a range of commodities. The SBP certification scheme exists as a tool for demonstrating compliance with regulatory, including legality and sustainability, requirements for woody biomass.
The mechanics of the SBP scheme and, in particular, the decision-making process for approving certifications need explaining, but first the SBP scheme should be put into context. The SBP scheme is founded on the two principles of legality and sustainability. Those principles are broken down into criteria and again into indicators, of which there are 38 in total covering a range of requirements, including ensuring compliance with local laws, ensuring features and species of outstanding or exceptional value are identified and protected, and ensuring regional carbon stocks are maintained or increased over the medium to long term (all the indicators are given in SBP Standard 1: Feedstock Compliance Standard). Each of the indicators has specific guidelines and reporting requirements.
There are five other SBP Standards covering how to evaluate the sustainability of the feedstock material, including requirements for stakeholder consultation and public reporting, how third-party verification is to be undertaken, and requirements for data transfer and chain of custody. Other processes, such as those for dealing with appeals from certificate holders and complaints from any interested party, are also provided.
SBP is built on existing and well-proven forest certification schemes, such as the Forest Stewardship Council (FSC) and the Programme for Endorsement of Forest Certification schemes (PEFC), but it does not intend to compete with or replicate them. There is, however, limited uptake of forest certification in some key feedstock source areas, for example, in the southeast US. Moreover, the aforementioned schemes, which were designed for retail wood products, do not cover all the regulatory requirements imposed on the use of woody biomass for energy production, in particular the collection, carriage and calculation of energy and carbon data throughout the biomass supply chain.
Therefore, SBP is unique in that it offers a certification scheme for woody biomass, mostly in the form of wood pellets and wood chips, used in industrial, large-scale energy production. Unlike FSC and PEFC, the first point of certification in the SBP scheme is the pellet/chip producer. The pellet/chip producer is assessed for compliance with the SBP Standards, specifically that the feedstock it uses is sourced both legally and sustainably.
In line with FSC and PEFC, that assessment must be carried out by an independent, third-party Certification Body. To avoid any potential conflicts of interest between the Certification Body and its client seeking certification, all SBP Certificaiton Bodies must be conformant with the ISO conformity assessment requirements for bodies certifying products, processes and services (ISO 17065). In addition, SBP goes further and requires all Certification Bodies to implement the requirements stipulated by either FSC, PEFC or SFI (Sustainable Forest Initiative) for undertaking audits.
A pellet/chip producer that satisfactorily demonstrates compliance receives a certificate and is entitled to make the claim that the biomass it produces is SBP-compliant. That does not mean that all biomass produced by the facility is sustainable, simply that if the certified management system is followed and the sustainability definition is met then the claim may be made. FSC or PEFC-certified feedstock, including feedstock with a certification claim from FSC or PEFC-approved schemes, is considered SBP-compliant. All other feedstock must be evaluated.
The process of evaluating the feedstock is termed the Supply Base Evaluation. The pellet/chip producer must carry out a risk assessment to identify the risk of compliance with each of the 38 indicators detailed in SBP Standard 1 (which contains the sustainability definition). Each indicator is scored as either ‘low risk' or ‘specified risk'. For any indicator scored as ‘specified risk,' the pellet/chip producer must put in place mitigation measures to manage the risk such that it can be considered to be effectively controlled or excluded. The mitigation measures must be monitored.
In conducting the risk assessment, the pellet/chip producer must consult with a range of stakeholders and also provide a public summary of the assessment for transparency purposes. The role of the independent, third-party Certification Body is to check that the evaluation of the feedstock has been correctly undertaken and that the pellet/chip producer can correctly make claims for the biomass produced.
Certain information is necessary if the end users, that is, those organisations using biomass to produce energy, wish to make claims relating to the legality and sustainability credentials of the biomass they use. SBP requires each legal owner of the biomass throughout the supply chain, from origin of the feedstock through trade, transport and processing, to supply that information. In order to meet the growing need for various greenhouse gas and profiling data demanded by the regulatory requirements of certain European countries, SBP defines the requirements and options for collecting data which must accompany SBP-compliant biomass.
In order to get the SBP scheme to market in a timely fashion, SBP undertook the role of approving the Certification Bodies. The approval process, which was based on the Accreditation Services International (ASI) accreditation process, was necessarily rigorous, and SBP called on accreditation experts to implement it. Amongst other things the process included SBP assessors (the accreditation experts) witnessing a Certification Body auditing a pellet/chip producer, mandatory approval of the Certification Body's audit team through training and examination, and a review of the whole assessment process by an independent technical committee.
Once the Certification Body has evaluated and assessed a pellet/chip producer and found it to conform with the requirements of the SBP scheme, SBP reviews all the supporting documentation using accreditation experts and the independent technical committee mentioned above. SBP insisted on that extra step of approval to introduce more rigour to the process.
In the interests of transparency, the approval procedures for Certification Bodies and Certificate Holders are published on the SBP website. For the avoidance of doubt, the SBP Board has no role in, or influence over, the approval decision-making process. A further, positive step in the development of the SBP scheme was made in early August when SBP entered into an agreement with the independent accreditation body, ASI, under which ASI now manages the SBP accreditation program and certification approvals. The agreement adds an extra level of independent scrutiny to the SBP scheme and enhances its integrity, which should be welcome news to the scheme's critics.
SBP is not a trade association representing its members' interests and has no role to play in arguing on matters of public policy. SBP exists because of the recognition by national governments and the European Union that biomass will make a significant contribution to meeting the energy needs of Europe in years to come. Such recognition demands that the biomass feedstock is sourced responsibly, that is, legally and sustainably. In the absence of any other suitable scheme to do the job, SBP has filled the void. SBP is willing to engage with all stakeholders in the interests of improving the understanding and acceptability of its certification scheme and in improving the standards and processes.
Debunking The Myths:
Myth 1: The SBP Board sets the Standards.
Fact: The Standards are drawn from the most stringent legality and sustainability regulatory requirements of European countries, in particular, Belgium, Denmark, the Netherlands and the UK.
Myth 2: The SBP Board approves certification decisions.
Fact: The SBP Board has no role in, or influence over, the certification approvals. SBP makes use of accreditation experts and forestry experts to review the certification decision of the independent Certification Bodies. Further, all certification decisions must meet the approval of an independent technical committee.
Myth 3: Certification schemes already exist that could do the job of SBP.
Fact: Existing forest level certification schemes do not cover all of the requirements faced by users of woody biomass for energy production, in particular, the combination of forest sustainability requirements, verification processes and the collection and carriage of energy and carbon data throughout the biomass supply chain.
Myth 4: SBP is not a credible system for verifying claims made by companies.
Fact: SBP has adopted the same certification processes as other well-known certification programs, such as FSC and PEFC, based on the stringent requirements of ISO 17065. An extra level of independent scrutiny has now been introduced through SBP's appointment of Accreditation Services International (ASI) to manage the SBP program for accrediting independent Certification Bodies.
Myth 5: SBP is an initiative by energy companies and is designed to protect their interests.
Fact: SBP was founded by companies in order to provide a solution; that is to allow companies to demonstrate the legality and sustainability of the biomass that they use. Importantly, the scheme's decision-making procedures are entirely independent of the energy companies.
Myth 6: Once issued a certificate, a wood pellet/chip producer can claim that all the biomass it produces is sustainable.
Fact: Issuing a certificate to a pellet/chip producer does not mean that all the biomass produced by that facility is considered sustainable. The certificate is issued to the pellet/chip producer when it demonstrates that it has a management system that enables the facility to make correct SBP claims when the feedstock it uses is sustainble.
Myth 7: SBP certificates provide no credible guarantee that the biomass is sustainable.
Fact: SBP Standard 1 sets the definition of sustainability and this definition is publicly available and transparent. The definition maps on to similar schemes, such as FSC and PEFC and is based on the biomass sustainability criteria of European countries, in particular, Belgium, Denmark, the Netherlands and the UK.
Myth 8: Certification Bodies are paid to issue certificates.
Fact: Certification Bodies are not paid to issue certificates, but rather to conduct certification assessments, whether the applicant passes or fails. Any potential conflict of interest is dealt with through application of ISO 17065, which sets requirements for Certification Bodies and essentially governs their behaviour to address that conflict. SBP requires all Certification Bodies to be conformant with ISO 17065 and, in addition, to implement the requirements stipulated by FSC, PEFC or SFI for undertaking audits.
Myth 9: Voluntary certification schemes are not credible.
Fact: The concept of certification processes and voluntary sustainability certification is well established and forms the basis for many of the purchases we make, from fire doors to seat belts, and from food and flowers to furniture and green building products. Further, such schemes are widely accepted by governments as acceptable solutions.
Myth 10: The SBP certification scheme allows companies to greenwash their activities.
Fact: There is no room for greenwashing within the SBP scheme. All of the SBP Standards are publicly available and transparent. SBP Standard 1 sets the definition of sustainability. The other standards set how sustainability is to be determined by the pellet/chip producer, how chain of custody is to be maintained, how greenhouse gas data are to be calculated and how the independent Certification Body will verify the operation of the pellet mill. In addition, all pellet/chip producers and Certification Bodies are required by the SBP Standards to conduct a stakeholder consultation process and reports are publicly available on the SBP website for scrutiny and comment.
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