Sustainability Considerations of a Biomethane Trade. William Mezzullo 21 Feb 2012

Transcription

1 Sustainability Considerations of a Biomethane Trade William Mezzullo 21 Feb 2012

2 Presentation Agenda Brief overview of discussion paper Comparison of Operating Sustainability Criteria Sustainability Considerations of the Criteria Summary & Conclusions

3 Discussion Paper Areas of Focus: 1. Overview of interpretation of Biofuels and Biomass Sustainability Criteria 2. Targets, mandatory/voluntary, end use energy, Voluntary Schemes etc. 3. Overview of National Sustainability Schemes Focus on Germany, NL and UK 4. Appreciation of experiences and difficulties encountered with Criteria adoption 5. Discussion of expected next guidance steps from Commission

4 Discussion Paper Next Steps: 1. Awaiting Commission s update on the Solid and Gaseous Sustainability Criteria 2. Better understanding of how the Criteria is being implemented in relevant Member States (i.e. those who are actually using a Criteria). 3. Further analysis of other environmental concerns of biomethane from Member States 4. Analysis of definition of waste and residue

5 Sustainability Criteria in Operation (bioliquids & biofuels): Criteria must be those as set out in Article 17 of the EU Renewable Energy Directive (published June 2009) Member states can only provide support to bioliquids that meet these, but cannot impose tougher criteria The RED Criteria for Bioliquids (& Biofuels) are 3-fold: Minimum GHG emissions saving of 35% compared to fossil fuel, increasing in 2017 to 50%; and in 2018 increases to 60% for new installations General restrictions on using raw materials from land important for biodiversity or as a carbon sink If crop is grown in EU must meet CAP cross-compliance requirements

6 Sustainability Criteria in Operation Solid & Gaseous: The EU, reported in February 2010 It did not mandate sustainability criteria for solid and gaseous biomass across the EU, instead member states can choose whether or not to introduce criteria But where members states do introduce criteria the EU strongly recommends that they: ensure that these in almost all respects are the same as those laid down in the Renewable Energy Directive. This would ensure greater consistency and avoid unwarranted discrimination in the use of raw materials.

7 Comparison of Member States experienced using Sustainability Criteria Germany Private Certification Schemes RedCert and ISCC for example BLE as National Auditing Body BLE supportive of making Solid & Gaseous Mandatory Very well established compared to other Member States BLE states that 80% of domestically produced biomass can be considered sustainable according to RED-criteria BLE seeking individual Sustainability Criteria for biomethane

8 Comparison of Member States experienced using Sustainability Criteria Netherlands NTA 8080 Netherlands Technical Agreement Scheme is owned by Dutch Standardization body NEN Applicable to Solid, Liquid and Gaseous biomass (part of subsidy scheme) Solid & Gaseous has been introduced for over a year NEN supportive of making Solid & Gaseous Sustainability Criteria mandatory from the European Commission NEN reporting on practical experience of NTA 8080

9 Comparison of Member States experienced using Sustainability Criteria UK Mandatory Sustainability Criteria for Transport (RTFO) Adopted Sustainability Criteria for Solid & Gaseous 60% GHG reduction Solid & Gaseous Criteria operating since April 2011 (linked to subsidies from April 2013) Only linked to some financial subsidies (ROC and not Feed-in Tariff) EC needs to make Solid and Gaseous Criteria Mandatory Sustainability Criteria launched for solid and gaseous to electricity only

10 Issues regarding Land-Use Change 1. EC report in Dec 2010 highlighted uncertainties of measuring LUC 2. Expected report from Commission 3. Recent new study for EC highlights significant impact of LUC 4. Reports concludes LUC should be a legitimate part of Biofuel policies 5. Acknowledgement that individual crop LUC will be difficult to achieve Assessing the Land Use Change Consequences of European Biofuel Policies Final Report October 2011 This report has been prepared by: David Laborde (IFPRI) ATLASS Consortium Specific Contract No SI implementing Framework Contract No TRADE/07/A2

11 Issues regarding GHG 35% GHG reduction this = gco2/mj 56 gco2/mj 67gCO2/MJ?

12 Issues regarding GHG Comparator Biogas to electricity 128gCO2/MJ Biogas to Grid 44gCO2/MJ gCO2/MJ 34gCO2/MJ gCO2/MJ 27gCO2/MJ

13 GHG Comparator for biomethane 1. Industry feeling (in the UK at least) is that differing criteria targets for electricity, heat, cooling, and transport may skew investment decisions 2. Taking NL example (and proposed UK example) adopting Biograce Natural Gas as a GHG comparator will make biomethane GHG reduction more difficult to achieve than say for electricity 3. If Biograce Natural Gas comparator is chosen is this really the same as comparing EU s electricity emission? 4. Sustainability Criteria could indirectly steer away biomethane installations to electricity installations.

14 Sustainability Criteria & Biodiversity 1. Criteria focuses specifically on prohibiting use of land with high biodiversity value 1. Highly biodiverse grassland 2. Designated nature protection 3. Primary forest Where are feedstocks typically grown for biomethane? 1. Locally sourced (low haulage due to over 70% water) dictated by cost 2. Fitting in with arable crop rotation (AD plant situated near farms) 3. No imports (very rarely) 4. Industry is unlikely to be using non-arable land for current biomethane feedstocks

15 Are the biodiversity requirements adequate? 1. Government Environment & Farming Bodies not convinced 2. Questions still being raised of biodiversity impacts of maize monocultures in Germany 3. Claims: 1. Considered to have low biodiversity benefits 2. Claims of loss of habitat for species 3. C4 plant water efficiency can lead to nutrient run off

16 Sustainability Considerations The use of energy crops in AD Industry Response: Benefits of farming break-crops Evidence of wildflower & improved biodiversity feedstock Careful management of energy crop production

17 Sustainability Considerations Fugitive methane emissions Concerns over fugitive methane emissions from AD IPCC data = 10%! DEFRA/DECC (UK Government Departments) need reassurance of what it is Evidence: BioGrace Project = 0.01MJCH4/MJ biogas (1%) Technology suppliers: Thöni = less than 1%, Agraferm = less than 1% Still concerns over fugitive methane emissions from biomethane upgrade

18 Sustainability Considerations How is the farming sector responding Developing additional Voluntary Code of Practice Adoption of National & Regional (more local) Environmental Farming Best Practice Schemes to enhance for example: Better hedgerow management Ditch management Management of field corners Wild bird seed mixtures 12+m buffer strips near watercourses (Cross-Compliance offers marginal biodiversity benefits In summary promoting environmentally responsible farming using Nationally Recognized Schemes

19 Summary & Conclusion The need for a mandatory Solid & Gaseous Criteria Concerns/Issues of Sustainability Criteria specifically to Biomethane GHG Comparators Biodiversity providing further evidence of benefits Outstanding environmental considerations should be considered by the Commission Need for a separate Biomethane Criteria (or better clarification for biomethane in the Solid & Gaseous)

20 William Mezzullo Thank you