EN    EN EN 
 
EN    EN  EUROPEAN COMMISSION  
Brussels, 25.2.2010 
SEC(2010) 65 final 
  
COMMISSION STAFF WORKING DOCUMENT 
IMPACT ASSESSMENT 
  
Accompanying document to the 
 
Report from the Commission to the Council and the European Parliament on 
sustainability requirements for the use of  solid and gaseous biomass sources in 
electricity, heating and cooling 
   
COM(2010) 11 final 
SEC(2010) 66 final 
 
EN 2   EN Lead DG: TREN 
Other involved services: ENV, ENTR, AGRI,  ECFIN, COMP, TAXUD, DEV, RTD, SG, 
JRC, TRADE, RELEX 
Agenda planning or WP refere nce: TREN WP 2009 Item 37 
Section 1: Procedural issues and co nsultation of interested parties 
• Organisation and timing  
Article 17(9) of the Renewable Energy Directive1 (RES Directive) requires the Commission 
to report by 31 December 2009 on requirements for a sustainability scheme for energy uses of biomass (other than biofuels and bioliquids), where appropriate, accompanied by proposals for a sustainability scheme. 
The report is in the Commission's Work Programme for December 2009/ January 2010 
(TREN WP 2009 Item 37). 
An inter-service steering group was establ ished. The first meeting took place on 9
th October 
2008 to introduce the timetable for the report and the steps to be taken in elaborating an IA. 
Two external studies (see details below) were introduced (a third having being concluded in 
February 2008) and services were invited to  participate throughout the timeframe of the 
studies. A second meeting took place on 19 Marc h 2009 to debate the policy options and to 
update the services about the external studies a nd about expert group meetings. A third 
meeting took place on 19 May 2009 to finalise the policy options and to discuss the presentation of impacts. The last meeting took place on 5 August 2009 to discuss the final 
draft impact assessment.  
The Impact Assessment Board issued its opinion on 28
th September 2009, recommending 
clarification of the dis tinction between the effects of a sustainability scheme and the effects of 
increasing use of biomass. It also asked that the administrative impacts be assessed using the 
EU's Standard Cost Model and that the impact on  third countries be made clearer. Finally the 
Board asked that the report explain the potential impacts of international negotiations with 
regard to accounting methods on land use land  use change and forestry (LULUCF). These 
points have been addressed in this fina l version of the Impact Assessment.  
• Consultation and expertise  
A public consultation was carried out July-S eptember 2008. 252 responses in total were 
received, of these, 243 have b een taken into account, due to some replies being sent more than 
once and/or from the same business associat ion and therefore have been taken into 
consideration only once.  
The questions covered five areas: – General questions about the appropriateness and scope of  a biomass sustainability 
scheme 
                                                
 
1 Directive 2009/28/EC 
 
EN 3   EN – Consideration of the greenhouse ga s methodology – based on the methodology 
proposed in Annex V of the RES Directive) 
– Consideration of promoting end-conversion efficiency 
– Consideration of other environmental sustainability criteria such as for sustainable 
forest management  
– Verification of sustainability criteria 
8% of the respondents were public  authorities, 22% were citi zens and the rest came from 
organisations, among which 58% were industr y and business, and 7% non-governmental 
organisations and research institutions. The results are further elaborated in section 3, but 
overall there was a large consensus that sustai nability requirements for biomass are necessary.  
Many stakeholders called for consistency with the sustainability scheme for biofuels used for 
transport as laid down in the RE S Directive, and claimed that th e sustainability scheme should 
not have different treatment for other biomass used for energy purposes. Consistency is also 
important for the development of the internal market. 55% of respondents advocated a legally 
binding scheme, where only biomass which meets sustainability criteria would count towards 
the national renewable energy targets laid dow n in the RES Directive. 18% advocated a 
legally binding scheme where biomass producer s (biomass from agriculture, forestry and 
waste) could only place sustainable biomass on  the market, and 10% thought that legally 
binding requirements should be set for electrici ty and heat producers (excluding households) 
to procure only sustainable biomass. Those w ho advocated a type of legally binding scheme 
believed that voluntary schemes are not reliable and give too much leeway to individual 
interests. 
17% of respondents thought that such criteria should be non-binding, as they considered that 
existing voluntary schemes, such as for sustainabl e forestry are sufficient. Most proponents of 
a voluntary scheme came from fo rest-based industry and argued  that legally binding schemes 
are not practicable because they reduce flexibility for new biomass markets and could discriminate against small-scale producers, and that they are not jus tifiable without also 
having legally binding schemes fo r other biomass uses such as paper, furniture, etc.  
On the question of minimum greenhouse gas (GHG)  requirements for biomass, the majority 
of respondents (58%) were in favour of a minimum GHG sa ving of 35%, (i.e. the same 
threshold as for biofuels and bioliquids as  the Commission proposed in the RES Directive
2). 
18% of the respondents (including some public authorities and environmental organisations) 
advocated a threshold figure whic h should be higher than for biof uels for transport, whereas 
5% argued for a threshold figur e lower than for biofuels (e .g. waste industry). 19% of the 
respondents objected to setting requirement s for GHG savings for biomass in general 
(including forest-based industry).  
On the question of promoting efficient en ergy conversion, there was wide support among 
respondents for using resources efficiently but some argued that energy-conversion efficiency 
should be treated separately because effici ency requirements might discourage biomass 
development and rather encourage fossil fuels for which criteria are not imposed. 
                                                 
2 The RES-Directive in fact lays down 35% GHG saving increasing to 50% GHG saving in 2017 for 
established installations and 60% GHG savings from 2018 for new installation. 
 
EN 4   EN On sustainable production of biomass, 67% of  respondents were in favour of sustainable 
forest management criteria for forest biom ass, but the 33% of respondents who opposed 
sustainable forest management criteria consid ered that proper implementation of existing 
criteria defined by the Ministerial Conferen ce on the Protection of Forests in Europe 
(MCPFE) and other voluntary schemes for forest , such as the Forest Stewardship Council 
(FSC), the Programme for the Enforcement of  Certification Schemes (PEFC) etc., are 
sufficient. Most of those who opposed  came from the forest sector.  
Some stakeholders, including inte rnational organisations, said th at experience with existing 
certification schemes can help to build on existing schemes so that costs can be kept to a minimum. It was stressed furthermore that sp ecific guidance and regu lation of biomass for 
energy purposes should be simple and should allow simple methods of production by small-
scale producers. 
The results of the public c onsultation can be found at: 
http://ec.europa.eu/energy/renewabl es/consultations/2008_09_30_biomass_en.htm
  
Three external studies were commissioned:  
1. Contract No TREN/D1/2008/FV489-1/SI2.512885 on "Technical assistance to implement 
the EU Biomass Action Plan: eval uation of options to promote bi omass efficiency", carried out 
by ECORYS NL in cooperation with Ecofys NL. The contract started in December 2008 and final report was submitted in June 2009 (Ecorys, 2009). 
2. Contract No TREN/D1/2008/FV-490-1/SI 2.528333 on "Technical assistance for an 
overview of international trade opportunities for sustainable biomass and biofuels", carried out 
by the COWI Consortium consis ting of ECN Energy Research Centre of the Netherlands, 
Copernicus Institute at Utrecht University, Forest and Landscape Denmark at the University of 
Copenhagen, COWI A/S and ControlUnion Certifi cations. The contract started in April 2009 
and final report on tasks 1 and 2 (global availab ility and impacts of sustainability schemes) 
were submitted end July 2009. A final report on Task 4 on assessing options for certifying 
chain of custody for forest products and fore st management was submitted at the end of 
October 2009 (The COWI Consortium 2009).  
3. A study by the Biomass Technology Group BTG BV
3 on "Sustainability Criteria and 
certification systems on sustainable biomass pr oduction" was finalised in February 2008 and 
served as an input into the assessmen t (BTG, 2008). The study is available at: 
http://ec.europa.eu/energy/rene wables/bioenergy/doc/sustainab ility_criteria_and_certification
_systems.pdf .  
The Commission organised and attended various  conferences and stakeholder meetings, 
including: MCPFE ad-hoc working group on biom ass sustainability on 12 January (Brussels) 
and 18-19 February (Lichtenstein) 2009, 11- 12 June 2009 (Sweden), DG TREN workshop on 
biomass sustainability held on 18 March 2008  (Brussels), DG TREN and AEBIOM jointly 
organised conference "Sustainable Bio-energy Strategies" held on 9 February (Brussels), 
Dutch Ministry of Economy workshop on GHG pa thways for biomass held on 7 April 2009. 
                                                 
3 BTG (2008) "Sustainability criteria and certificati on systems on sustainable biomass production", The 
Netherlands 
 
EN 5   EN The Commission’s minimum standards for consultation were all met. 
Section 2: Problem definition 
• What are the underlying drivers of the problem ? What is the issue or problem that may 
require action?  
The EU needs to increase its use of biomass for energy purposes to reach the 2020 targets 
agreed under the RES Directive (in order to contribute to reduce overall greenhouse gas 
emissions, increase competitiveness and the security of energy supply).  
Biomass is a renewable energy source. Where biomass is used, it is important to have 
measures in place to encourage regeneration (in forestry and agriculture). As biomass 
resources are not infinite, its effici ent use should also be encouraged.  
For the purposes of this IA, only solid and gaseous biomass used for electricity and heating 
are under consideration as transport biofuels a nd bioliquids are covered by a sustainability 
scheme under Articles 17-19 of the RES-Direc tive. BOX A below expl ains the different 
biomass sources and energy conversion routes.  
BOX A - Biomass sources and energy conversion routes 
Biomass refers to "the biodegradable fraction of products, waste and residues from biological 
origin from agriculture (incl uding vegetal and animal substa nces), forestry and related 
industries including fisheries and aquaculture,  as well as the biodegradable fraction of 
industrial and municipal waste"4. Using various transformation processes such as combustion, 
gasification, pyrolysis the bioma ss is either transformed into transport biofuels, bioheat or 
bioelectricity. 
Biomass originates from forest (logs, bark, wood ch ips, sawdust, pellets et c) agriculture (rape, 
wheat, maize etc) and waste streams (municipa l solid waste, post consumption wood waste, 
refuse-derived fuels, sewage sludge, etc.), but can be virtually any organic material. 
Each biomass resource has different characteristics in terms of calorific value, moisture and 
ash content, etc. that  require appropriate conversion t echnologies for bio-energy production. 
These conversion routes use chemical, thermal a nd/or biological processes, and can be used 
for transport, electricity or heating as follows:  
                                                 
4 As defined under Article 2(e) in Directive 2009/28/EC 
 
EN 6   EN 
 
The first issue to consider is biomass availability. There is a variety of literature on the future 
availability of biomass for ener gy purposes. In its proposal for a Renewable Energy Directive, 
the Commission based its assumptions on bioma ss availability on a study carried out by the 
European Environment Agency (EEA)5, which estimated that around 235 Mtoe of EU-
produced biomass will be available in 2020 for energy use.  
The Commission asked the COWI Consortium to assess the wider literature on this issue for 
2020-2050 (COWI Consortium 2009). The report finds  that the largest difference between 
study results for the availability of bioma ss for energy production is due to the assumed 
availability of land, which, in  turn, is heavily influenced by productivity development 
assumptions and development of technology. It  was found that the EEA's assumptions are 
relatively conservative, as EEA considers lo wer productivity growth estimations due to 
environmentally sound farming (e.g. organic fa rming) for 2020 and doe s not cover Romania 
and Bulgaria. 
The COWI Consortium (2009) report concludes that between 2020 and 2050 the availability 
of land for biomass energy and of also forest biomass will continue to increase, because the 
population in Europe is projecte d to decrease, the consumption of food is saturated, while the 
efficiency of agriculture is projected to incr ease. The biomass estimates of EEA and of the 
modelling scenarios by Green-X for 2020 6 were compared with other available studies. It was 
concluded that most Green-X assumptions on costs and potentials ar e reasonable given the 
literature sources, but that the Green-X mode l may be optimistic on the availability and 
                                                 
5 EEA (2007): Environmentally compatible bio-energy  potential from European forests. Copenhagen, 
European Environment Agency 
6 As presented in the EMPLOY-RES study available at: 
http://ec.europa.eu/energy/renewables/studie s/doc/renewables/2009_employ_res_report.pdf 
 
EN 7   EN (particularly) the low costs of  forestry products and residues,  which could be caused by the 
differences in oil price assumptions.  
Even if adequate sustainable biomass availabilit y is presumed to meet the EU's 2020 targets 
domestically, there is a risk of negative envir onmental impacts, linked to the increased use of 
the resource and increased imports.  
Biomass is an easily tradable good and envir onmental protection or sustainable energy 
policies are not uniform across the EU or i ndeed outside the EU where biomass can be 
imported from. Public intervention is justified where an intensified use of biomass leads to 
environmental risks in the following five areas: 
1) Production of biomass (land mana gement, cultivation and harvesting)  
- market failures leading to unsustainable production of resources (negative externality) e.g. 
emissions arising out of land use change, are not  reflected in market prices, and potential 
negative impacts on biodiversity, wate r, soils and ecosystem services.  
- regulatory failure: renewable en ergy policy encourages Member States to use more biomass 
to meet their targets, while rules or prici ng mechanisms for biomass production do not always 
take into account negative external ities, such as deforestation.  
In Europe, the risk of deforestation is very low,  and in fact European forests have increased in 
area, growing stock and standing volume in r ecent years (Eurostat). Nevertheless, there are 
market failures in forestry at a global level, as the societal and environmental benefits of forests are not correctly priced. In developing countries in pa rticular, there is a lack of 
coherent sustainability rules and regula tions with regard to biomass (FAO, 2009
7).One of the 
root causes behind deforestation in the devel oping world is the weak governance structure for 
forest conservation and sustainable management of forest resources.  
At a global level, the Unite d Nations Framework Convention on Climate Change (UNFCCC)8 
is currently discussing a new agreement in cluding on how to account for emissions and 
removals from forests as well as how to redu ce emissions from defore station in developing 
countries. Should these processes fail to correct the market failures, there would be concerns, 
in particular for imported biomass, that increas ed demand may lead to loss of forest area, 
volume or quality, or wetlands being drained to  increase productive land  area, leading to a 
negative impact on na tural biodiversity.  
In Europe, environmental risks are more to do wi th new practices arising from the intensified 
use of forests. This includes practices such as stump extraction and th e increased removal of 
other forest residues. There is relatively  little known about the risks posed by stump 
harvesting, in particular because it is not common practice in th e EU. Initial research suggests 
that if stumps are ha rvested in vulnerable areas, it may le ad to soil damage, carbon loss, 
erosion and increased turbidity and siltation of  local watercourses. The removal of essential 
nutrients (e.g. nitrogen, phosphor us, potassium and boron), could also lead to lower soil 
fertility, and potential loss of tree growth in subsequent rotations. Removal of base cations9 
                                                 
7 FAO (2009) "Small-scale bioenergy intiatives", ftp://ftp.fao.org/docrep/fao/011/aj991e/aj991e.pdf   
8 http://unfccc.int/2860.php   
9 Base cations are the most prevalen t, exchangeable and weak acid cations in the soil, including ions such 
as calcium (Ca2+), magnesium (Mg2+) potassium (K+) and sodium (Na+) 
 
EN 8   EN (calcium, magnesium, sodium and potassium) can also lead to reducing soil buffering 
capacity and lead to increased soil and stream  water acidification (see Forest Research UK, 
2009 interim guidance10). The total carbon emissions duri ng harvesting and supply of stumps 
as well as utilisation of wood ash as a compensa tory fertiliser corresponds to 5.6 % of carbon 
content in biomass, according to the Forest Research Institutes of Latvia and Sweden11. 
Similar uncertainties exist abou t removing branches and leaves (i.e. other forest residues), 
which are important sources of forest nutrien ts, necessary to maintain soil and ecosystem 
health (UN-Energy, 200712). More research is necessary to determine how much forest 
residue can be removed safely to avoid degrading soil qual ity and reducing yields. These 
forest management practices can lead to ove rall carbon stock change s. Regulatory failures 
come from the lack of information on these practices.  
In agriculture, there is a risk that intensive ferti lisation of agricultural land to get better yields 
might lead to high nitrous oxide (N2O) emissions  and risk of increased  water consumption or 
pollution. The systematic removal of agricu ltural residues like st raw for heating may 
deteriorate soil organic matter (and therefore carbon balance) and soil fertility, lead to 
intensified use of grasslands and more fr equent cutting of hedges which may endanger 
biodiversity. Management practices (int ercropping, crop rotation, double cropping and 
conservation tillage etc.), can overcome some problems. Although unsustainable practices are 
not usually in the interest of land users/owners, their intere st for short-term profits can 
outweigh the importance of long-term productivity. However, in the EU, ag riculture is subject 
to a set of environmental rules under the Common Agricu lture Policy and under common 
environmental rules. 
2) GHG performance throughout the whole chai n (production (cultivation/harvesting) – 
transport - processing – transformation):  
– regulatory failure if biomass used for en ergy purposes does not lead to GHG savings 
compared to fossil alternatives The risk of not achieving high GHG savings is lower than the 
risks identified for biofuels used in transpor t, because the processing steps (e.g. pelletisation) 
generally consume less energy than the processe s required to make tr ansport biofuels. It 
should be noted however, that while biogas from  waste generally has a very favourable GHG 
profile, biogas production from agricultural cr ops can lead to more emissions due to 
emissions associated with the production phase.  
3) Inefficient conversion of resource to usef ul energy - a lack of clear and/or common 
standards/ rules for using biomass feedstocks e fficiently leads to processes which may lead to 
an overuse of resources.  
– regulatory failure because sometimes the in efficient use of biom ass is given state 
support 
                                                 
10 http://www.forestry.go v.uk/fr/INFD-7RBJ23   
11 Andis et al (May 2009) "Productivity and cost of stump harvesting for bioenergy production in Latvian 
conditions", http://tf.llu.lv/conference/proceedings 2009/Papers/33_Andis_Lazdins.pdf , LSFRI and 
SKOGFORS 
12 UN-Energy (2007) "Sustainable energy: a framework for decision makers" 
http://www.fao.org/docrep/010/a1094e/a1094e00.htm   
 
EN 9   EN – market failure also exists as imperfect in formation and lack of transparency in the 
market makes households unaware of the opportunities for energy savings in the 
long-term, by switching to more efficient heating technologies. 
4) Local emissions - Traditional uses of bio-en ergy (open stoves for heating and cooking) can 
affect the health of people, cau sing respiratory diseases. Howeve r, the impact assessment will 
not deal with these risks because local emi ssions are also regulated by other European 
legislation, such as Directive 2008/50/EC which sets standards and targ et dates for reducing 
concentrations of fine particle s, which together with coarser particles known as PM10 already 
subject to legislation, are among the more da ngerous pollutants for human health. Local 
emissions from small-scale plants are regulate d at national/regional level, and there are 
European standards developed by CEN (EN 303-5 for biomass boilers of below 50 kW, 50-150kW and 150-300 kW output), setting emissi ons limits for carbon monoxide (CO), 
unburned hydrocarbons or or ganically bound carbon (OGC)
13 and for particles. Labels have 
been developed in some Member States to ce rtify low emissions, e.g. P-Mark (Sweden) and 
Swan Label (Nordic countries).  
5) Risks associated with using biomass waste for energy purposes are also regulated by other 
policy measures14 and biomass from non-agricultural and non-forest waste15 will not be 
tackled by this impact assessment. The issue of using biomass wast e (including municipal 
solid waste, biowaste, sewage  sludge) for energy rather th an for other purposes e.g. 
composting or fertilising, is an issue to be  tackled under the implementation of the Waste 
Framework Directive. For instance, in case of  municipal solid waste, waste incinerator 
operators have to meet a give n energy efficiency threshold. 
Positive effects of using biomass should not be forgotten: lower risk of forest fire from 
removing branches and leaves on ground, improved GHG performance in energy, benefits for stabilisation of forest stands and reduction of ri sk of insect infection, economic benefits like 
diversification of income possibilities for farm ers and forest owners and rural areas as a 
whole. Positive impacts could arise from pere nnial grasses or short rotation coppicing grown 
on agricultural land, by in creasing the soil carbon content as  compared to annual agricultural 
crops (UN-Energy, 2007
12). Possible indirect impacts on land use are therefore considered to 
be lower than for biofuels and bioliquids and may well be positive. The Commission has been 
asked to prepare a report on the effects on indirect land use chan ge of increasing the 
                                                 
13 The development of pellet burners (and stoves) has so far been focused on achieving low emissions of 
OGC, but as there is a trade off between CO/OGC and NOx emissions, this has resulted in combustion 
devices with relatively high emission of NO x. (Eskilsson et al, 2002) 
14 2001/80/EC or the Large Combustion Plants Directive aims toreduce emissions of acidifying pollutants, 
particles, and ozone precursors from larg e combustion plants greater than 50 MW; Directive 
2001/81/EC  of the European Parliament and the Council on National Emission Ceilings for certain 
pollutants (NEC Directive) sets upper limits for each Member State for the tota l emissions in 2010 of 
the four pollutants responsible for acidification, eutrophication and ground-level ozone pollution (sulphur dioxide, nitrogen oxides, volatile organi c compounds and ammonia); Directive 2008/1/EC on 
Industrial Pollution Prevention and Control (IPPC) is about minimising pollution from various 
industrial sources and sets permit conditions includ ing emission limit values based on Best Available 
Techniques (BAT), also for biomass plants a bove 50MW; The 2001/76/EC directive on waste 
incineration sets emission limit values and monitoring  requirements for pollutants to air such as dust, 
nitrogen oxides (NOx), sulphur dioxide (SO2), hydrogen chloride (HCl), hydrogen fluoride (HF), heavy metals and dioxins and furans. 
15 For the purpose of this impact assessment, waste fr om agriculture and forestry will be referred to as 
processed agricultural and forest residues 
 
EN 10   EN consumption of biofuels and bi oliquids by 2010. The results of th at work will give indications 
on whether or not the indirect land use cha nge impacts of other commodities should be 
studied.  
• Who is affected, in what ways, and to what extent?  
Today the global trade in biomass is below 2% of  the total biomass used  for energy, but in the 
long term some projections expect global  biomass trade to rise substantially16. If this 
contributes to forest areas decr easing globally (in part icular in the highly bio-diverse tropical 
regions) or to degradation of the soil or water quality, entire ecosystems and species may be 
affected, including the long-term welfare of pe ople who depend on the forest for income or 
for living. Some developing count ries in particular depend on forest products for income. 
Nevertheless, it is to be noted that EU forests continue to increase their growing stock and the 
use of biomass in the EU has positive effects on  job and income genera tion, diversification of 
enterprises and rural economies.  
If biomass is used inefficiently, it may not c ontribute to mitigating climate change and scarce 
resources may be partly wasted. It is difficult to say however who will be affected if undesirable practices remain.  
• How would the problem evolve, all things being equal?  
It is important to recall here that this impact  assessment does not look at the impact of the 
increased use of biomass. The impact asse ssment looks at the impacts of introducing 
sustainability criteria. The baseline scenario developed below does howe ver take account of 
the projected increases in the use of biom ass, as the baseline scenario includes the 
presumption that the 2020 renewable energy targets will be met.  
To ensure maximum consistency with existing EU scenarios and projections, the baseline is 
derived from the EMPLOY-RES
17 study, ‘advanced deployment po licy’ scenario, which uses 
the Green-X model and has used input  parameters derived from PRIMES18 modelling 
(efficiency case) and from recent assessments of the European renewable energy market 
(FORRES 202019, OPTRES20, PROGRESS21).  
The baseline scenario assumes that 177.5 Million t onnes of oil equivalent (Mtoe) biomass will 
be used for energy purposes in the EU in 2020 (t he realisable potential is projected by Green-
                                                 
16 Umweltbundesamt, Ökoinstitut, IFEU (2009). Sustainable Bioenergy: Current Status and Outlook; 
March 2009 
17 Ragwitz M, Schade W, Breitschop B, Walz L., He lfrich N, Rathmann, M, Re sch G., Panzer C, Faber 
T.,., Held A., Haas R, Nathani C, Holzhey M, Konsta ntinavicitute I, Zagame M, Fougeyrollas A, Le Hir 
B, "The impact of renewable energy on growth and employment in the European Union" 
http://ec.europa.eu/energy/renewables/studie s/doc/renewables/2009_employ_res_report.pdf   
18 The European Energy and Transport Tr ends by 2030 /2007/ Efficiency case - 
http://ec.europa.eu/dgs/energy_transport/figures/trends_2030/index_en.htm   
19 Ragwitz M, Schleick J, Huber C, Resch G., Faber T,  Voogt M, Coenraads R, Cleijne H, Bodo, P (2005) 
"FORRES 2020: Analysis of the Renewable Energy Sources evolution until 2020", Karlsruhe, Germany 
20 Ragwitz M, Held A, Resch G., Faber T, Haas R, Huber C, Coenraads R, Vo ogt M, Reece G, Morthorst 
P, Jensen-Risoe S, Konstantinavicitute I (2007)  "Assessment and Optimisation of renewable energy 
support schemes in the European elect ricity market", Karlsruhe, Germany 
21 Coenraads R, Reece G, Voogt M, Ra gwitz M, Held A, Resch G., Faber T, Haas R, Konstantinavicitute 
I, Krivosik J, Chadim T (2008) "PROGRESS: Promotion and growth of renewable energy sources and 
systems", Utrecht 
 
EN 11   EN X to be 221.6 Mtoe in  2020, excluding imports) in primar y energy. Annex I gives detailed 
information about the breakdown of realisable potentials for 2020 and the corresponding fuel 
costs for the considered biomass options.  
On energy conversion efficiency, 16% energy demand reduction is assumed by 2020 in the 
baseline scenario, due to a stimulation of ‘tec hnological learning’ and due to existing policies 
on energy efficiency22. Energy efficiency of renewable en ergy plants is also incentivised by 
the fact that the accounting for renewable energy target is in terms of final energy consumption, meaning that avoiding losses in creases the renewable energy share counting 
towards the target. This especi ally incentivises  biomass heating, where losses are low. Annex 
II shows the baseline efficien cies assumed for specific bio- energy technology combinations.  
The baseline scenario for land use is more di fficult to determine. Europe has seen increased 
afforestation, while globally gross deforestation is estimated at 13 million hectares a year 
(UNEP, 2008
23). It is difficult to quantify what pr oportion of this was due to bio-energy 
demand (CIFOR, 2009)24. Currently, the amount of imported forest biomass for energy use in 
the EU is not signifi cant (around 3 Mtoe mainly from Cana da and Russia), but in the baseline 
it is assumed that imports could more than double in 202025. 
Measures to address the issue of deforest ation and encourage afforestation are being 
developed. In Europe, the Ministerial Confer ence on the Protection of Forests in Europe 
(MCPFE)26 has produced detailed recommendations for forest management and protection. 
Community forest actions are based on the Forest Strategy for the EU27 and the EU Forest 
Action Plan28. The EU has also engaged in fighting deforestation with its Action Plan for 
Forest Law Enforcement, Governance and Trade (FLEGT)29 and the UNFCCC negotiations 
on reducing carbon emissions from deforestati on and forest degrad ation in developing 
countries (REDD30) are ongoing.  
International processes have also acknowledge d the importance of forest protection and 
sustainable forest management and increasi ngly, voluntary sustainability schemes are 
provided by companies, independent organisatio ns or through national or intergovernmental 
structures (see Annex III for an  analysis of developments in  the different sectors). The 
                                                 
22 These include the Eco-Design Directive, the Ener gy Star Regulation, the Labelling Directive, the 
Energy Performance of Buildings Directive, the Cogeneration Directive and the Directive on Energy 
End-Conversion Efficiency and Ener gy Services. The latter Directive sets an indicative target for EU 
Member States to achieve a 9 % energy saving by 2016 from new energy services and other energy 
efficiency improvement measures . Moreover, to achieve the ener gy efficiency target (through 
implementing energy effici ency legislation), Member States ha ve put in place energy efficiency 
obligation and White Certificates, end-conversion efficiency requir ements for biomass in support 
schemes, household subsidy schemes for efficient pellet boilers and investment grants for small CHP. 
23 UNEP, FAO, UNFF (2008) "Vital forest graphics: stopping the downswing?", UNEP/ Grid-Arendal, 
2008, http://www.grida.no/publications/vg/forest/   
24 Centre for International Forestry Research, CIFOR 2009 "A global analysis of tropical deforestation 
due to bioenergy development" Contract No. EuropeAid/DCI-ENV/2008/143936/TPS 
25 Green-X projections 
26 http://www.mcpfe.org/documents/r_2007/   
27 http://eur-lex.europa.eu/LexUriServ/LexU riServ.do?uri=COM:2005:0084:FIN:EN:DOC   
28 http://ec.europa.eu/agriculture /fore/action_plan/index_en.htm   
29 COM(2003)251 final and COUNCIL REGULATION (EC) No 2173/2005 
30 COM(2008)648/3 "Addressing the challenges of deforestation and forest degradation to tackle climate 
change and biodiversity loss" 
 
EN 12   EN UNFCCC31 recognises the importance of forests in  the global greenhouse gas balance. The 
Convention on Biological Diversity (CBD)32 has addressed forest biodiversity through an 
expanded programme of work containing 11 forest specific goals.  These initiatives could be a 
potentially promising approach in the battle to combat climate change, and to reduce the rate of forest and biodiversity lo ss. Voluntary and inter-governme ntal initiatives to fight 
deforestation and proposed requirements by th e European Commission on economic operators 
to exercise due diligenc e to avoid illegal logging
33, will also ensure increased impetus for the 
use of sustainable forest biomass.  
Carbon balances of forests are also difficult to estimate, due to uncertainties about the 
workings of the carbon cycle. The Internati onal Panel on Climate Change (IPCC) estimates 
that the amount of carbon abso rbed in the soil and vegeta tion amounts to approximately 1.1 
Gt/year. Due to inter-annual vari ability affecting both gains and losses, the net sink varies 
between approximately 0.9 and 4.3 Gt/year. Research is ongoing on how much carbon is 
emitted as a result of deforest ation and forest degradation. In  its 4th Assessment Report of 
2007, the IPCC said carbon emissions as a result  of land-use change – mainly due to 
deforestation in the tropics – we re running at 1.6 Gt of carbon per year in the 1990s (central 
estimate), or around 20% of the world’s tota l anthropogenic (manmade) emissions of 
greenhouse gases. According to the Effort Sharing Decision (ESD)34 and Emissions Trading 
Directive (ETS)35, the Commission will have to make a proposal related to Land Use and 
Land Use Change and Forestry (LULUCF36) in the Community GHG reduction commitment 
according to harmonised modalities as well as accurate monitoring and accounting. This 
suggests that forest carbon data should be  better harmonised in  the Community GHG 
inventory in future. However th is is a general issue rather than one specifically in energy 
policy. The relevance of LULUCF accounting to  energy policy and sustainability criteria for 
bio-energy in particular, is  discussed in section 4.1.1. 
The baseline scenario for employment is taken from a recent study for the Commission, 
which assessed the overall employment impacts of the renewable energy policy (EMPLOY-RES
37). It was found that total gross employment is expected to increase to 2.5 million in the 
EU-27, the majority of which would be in bi ofuels and biomass production. From additional 
biomass provision alone (fuel use effects), ar ound 1.2 million jobs are expected. There will be 
additional jobs associated with employment caused by producing the generation technology 
and plant (investment effects) and to run the generation facilities (operation and maintenance 
effects). The EMPLOY-RES study did not lo ok at employment impacts of introducing 
sustainability criteria for biomass, but it can  act as a benchmark for comparing impacts on 
employment due to the introduction of a sustainability scheme.  
For households, the baseline scenario assumes m oderate energy cost increases resulting from 
renewable energy policies. On local communities de pendent on forests, a baseline scenario is 
                                                 
31 UNFCCC - United Nations Framework Convention on  Climate Change Art 4 1. (d) – www.unfccc.int 
32 https://www.cbd.int/forest/portal/home.shtml  
33 COM(2008) 644 
34 ESD : Decision No 406/2009/EC of the European Parliament and of the Council of 23 April 2009 
35 Directive 2009/29/EC of the European Parliament and of the Council of 23 April2009 
36 UNFCCC OECD countries are required to make av ailable national inventories of anthropogenic 
emissions by sources and removals by sinks of all greenhouse gases (GHGs) not controlled by the 
Montreal Protocol, including inventories of GHG emissions and removals from the LULUCF sector. 
37 http://ec.europa.eu/energy/renewables/studie s/doc/renewables/2009_employ_res_report.pdf  
 
EN 13   EN difficult to construct, as it is related to wider economic and governance challenges, which 
cannot be addressed through renewable energy policy.38 
• Does the EU have the right to act – Treaty base, ‘necessity test’ (subsidiarity) and 
fundamental rights limits?  
EU has a right to act under Article 192 of the Treaty on the functioning of the European 
Union, to ensure the smooth functioning of the internal market and the protection of the 
environment.  
If no action is taken at EU level, it is likely th at there will be a comple x set of sustainability 
requirements developing at national or regi onal level for biomass used for heating and 
electricity (Annex III describes some of the national developments), with a possibility of raw material producers having to pr ove several criteria depending on the end market and therefore 
creating market distortions between different sour ces of biomass. For this  reason the legislator 
in the RES Directive specified that "if the analysis done […] demons trates that it would be 
appropriate to introduce amendments, in relati on to forest biomass, in the calculation 
methodology in Annex V or in th e sustainability criter ia relating to carbon stocks applied to 
biofuels and bioliquids, th e Commission shall, where appr opriate, make proposals to the 
European Parliament and Council at the same time in this regard ". 
If Member States would act alone, the internal  market may be disrupted  for biomass traders, 
suppliers and producers. The adde d value of the Community therefore is that the same rules 
would apply throughout the Community. There ar e however differences in Member States' 
support for bio-energy and land-use policy, which need to be kept in mind.  
Section 3: Objectives 
• What are the general policy objectives? What are the more specific/operational objectives? 
Underline the consistenc y of these objectives with other EU policies 
The general policy objective is to guarantee a su stainable use of biomass for energy purposes 
under the framework of the Renewable Energy Directive.  
The specific objective of this are to ensure that  heat and power uses of biomass leads to (1) 
sustainable production, (2) high GH G performance compared to fossil fuels and (3) efficient 
energy conversion of biomass into el ectricity and heating and cooling. 
The operational objectives are to establish sust ainability requirements for solid and gaseous 
forms of biomass used in electricit y and heating, as long as they are: 
– effective in dealing with problem s of sustainable biomass use,  
– cost-efficient in meeting the objectives and  
– consistent with existing policies.  
                                                
 
38 World Bank (2004) estimates that 1.6 billion people around the world depend to some degree on forests 
for their livelihoods "Sustaining forests: a development strategy", http://www-
wds.worldbank.org/servlet/WDSContentServer/WDSP/IB/2004/07/28/000009486_20040728090355/R
endered/PDF/297040v.1.pdf   
 
EN 14   EN These objectives are consistent with the EU's climate and energy policy objectives, including 
the RES-Directive and the EU's energy efficien cy action plan which aims to achieve a 20% 
energy saving by 2020 compared to business as usua l. The objectives are also consistent with 
the EU's policy on deforestation and forest degradation39.  
Section 4: Policy options 
The policy options are presented under the three areas of possible actions: 
– production of biomass 
– GHG performance across the whole life cycle  
– conversion of biomass to energy 
There are synergies between th e options identified under the Life Cycle Assessment (LCA) 
approach on GHG emissions, the production of biomass and the efficiency of energy-
conversion. This is because life cycle GHG emissions take account of emissions along the 
whole chain (from production to end use, in cluding emissions from land use change). 
However, high GHG performance cannot guarantee that  land is managed su stainably, or that 
the efficiency of the chain improves, as inefficient processes can also lead to high GHG performance. Therefore, all thr ee issues are studied separately  and the options under the three 
areas are not mutually exclusive.  
As far as the production phase of  biomass in concerne d, environmental effects of farming in 
the EU are mitigated through enforcing mandatory standards on "cross-compliance" through establishing a link between income payments to farmers and the respect of those standards. . 
Waste production and management is regulated by specific waste legislation in the EU. As a 
result, the policy options in the impact assessmen t focus on the sustainability of production of 
forest biomass. As far as agricultural producti on practices in third countries is concerned, the 
RES Directive settled that thes e would be tackled th rough appropriate re porting requirements. 
This question is not reconsidered  in the impact assessment.  
A summary table of the areas and options within are represented in Table 1 (the  three issues 
are further explained following the summary): 
Table 1: Summary table of options 
ISSUES and Options   
A. Production of 
biomass Policy Scenario 
 Synergies with other options 
Option A1: no new 
EU action Voluntary schemes continue to elaborate 
certification schemes for sustainable 
biomass production and land management.  B1 and C1 (business as usual) 
Option A2: Guidance 
on intensification 
methods in forestry Guidance on land use issues related to 
increased bio-energy production in forests 
e.g. increased use of stumps and branches Partly A1, as voluntary processes are 
considering such guidance  
                                                 
39 COM(2008)645/3 
 
EN 15   EN and leaves. 
Option A3: minimum 
criteria on 
biodiversity and land 
use  Criteria on biodiversity and land use (as 
agreed under RES Directive) or so-called 
'no-go' areas to apply to all biomass. Forest 
management issues are left out of the 
scope.  
(Section 5.1 elaborates the specific 
biodiversity and land use criteria) Partly B3, and B4 , as GHG 
methodology will account for negative 
land use change (as it does in RES-
Directive) 
Option A4a: Option 
A3 + reporting on 
biomass origin As Option A3, + reporting requirements on 
Member States on biomass origin. 
Commission (COM) to monitor if forests 
are regenerated by economic operators in 
areas of origin, if not, COM to propose 
corrective action. As for A3 
Option A4b: Option 
A3 + reporting on 
Sustainable Forest 
Management (SFM) As Option A3, + mandatory reporting 
requirements on Member States on 
sustainable forest management. 
Commission (COM) to monitor (including 
third countries) As for A3 
Option A5: Option A3 
+ SFM minimum 
obligations As Option A3, + obligations on Member 
States to count only forest biomass from 
SFM towards their renewable energy 
target. This requires a global definition of 
SFM and a verification mechanism and 
minimum requirements  e.g. on carbon 
balances, nutrients or forest vitality. As for A3 
Option A6: Option A3 
+ LULUCF 
accounting As Option A3, + eviden ce of good practice 
in case country of origin does not account 
LULUCF emissions  As for A3 
B. GHG savings*:   
Option B1: no new 
EU action GHG performance requirements are not 
necessary as most biomass used in heating 
and electricity contribute to an at least 50-
60% saving in GHG emissions compared 
to the next best fossil alternatives.  A1 and C1 (business as usual) 
Option B2: labelling 
of GHG performance Label GHG performance to give 
information to the consumer (electricity or 
heat consumers) and in order to promote 
GHG life cycle thinking for production 
processes in a wider context. A common 
GHG methodology for labelling would be 
necessary to ensure consistency of claims. 
The obligation could be placed on 
electricity and heat providers, and the GHG 
performance could be made available on 
guarantees of origin, for disclosure 
purposes. C4 (labelling requirements) – 
Guarantees of origin (GOs) for 
instance could be used to disclose the 
GHG performance as well as the 
efficiency of a plant  
Option B3: Setting 
minimum GHG 
savings requirements 
for biomass from 
agriculture and 35% minimum GHG saving requirement 
for agricultural and forest biomass 
(compared to fossil alternative) - same 
minimum requirement as for biofuels and 
bioliquids in RES Directive for consistency Partly A3 as GHG methodology 
account for negative land use change, 
but does not guarantee protection of 
biodiverse areas or high carbon stock 
areas.  
 
EN 16   EN forestry - 35% 
(increasing to 50-60% 
in 2017/2018)   Partly C3 if biomass pathways not able 
to meet minimum GHG threshold due 
to inefficient end-conversion 
technology.  
Option B4: minimum 
GHG requirements 
for forest and 
agriculture biomass in 
accordance with GHG 
saving potential  Introduce minimum GHG requirement in 
accordance with the Best Available 
Technology (BAT) in each pathway to 
ensure that each sector and pathway 
achieves best practice results. Partly A3 but do es not guarantee 
protection of biodiverse areas and 
avoidance of negative land use change  
Partly C3 if biomass pathways not able 
to meet minimum GHG performance 
requirements due to  inefficient end-
conversion technology. 
C. Conversion   
Option C1: No new 
EU action Existing energy efficiency policy will yield 
results in making the use of all energy 
resources, including biomass, more 
efficient.  A1 and B1 (business as usual) 
Option C2: Bonus for 
better end-conversion 
efficiency or penalty 
for lower end-
conversion efficiency Member States to give a bonus/penalty (i.e. 
financial incentive/disincentive) to improve 
efficiency through differentiating subsidy 
levels, or awarding additional green 
certificates.  None 
Option C3: banning 
inefficient use or 
minimum efficiency 
standards (for large 
scale installations 
above 1 MW) Banning certain inefficient biomass 
technology options or introducing 
minimum requirements. Small-scale 
(mainly residential) use is out of the scope 
as dealt with by other EU policy.  Partly B3, B4 and B5 if the inefficient 
technology is responsible for not 
meeting the minimum GHG threshold  
Option C4: labelling 
efficiency  Labelling to create awareness of the (end 
conversion) efficiency of a biomass 
pathway or installation e.g. biomass boiler, 
by giving insight into its performance. This 
can be done for consumer goods or for 
larger applications (above 1MW capacity) 
through labelling energy savings on the 
guarantee of origin. B2 (labelling criteria) - GOs for 
instance could be used to disclose the 
GHG savings as well as the efficiency 
of a plant 
Option C5*: improve 
supply chain 
efficiency A GHG life cycle methodology to include 
end-conversion efficiency.  Partly B2, B3, B4 – if the GHG 
methodology includes end-conversion 
efficiency 
* On improvement of GHG emissions in the whole chain, methodological questions need to be addressed. The 
policy options under part B deal with the question of whether and to what extent  there should be minimum 
requirements for GHG performance for the different biomass chains, but option C5 is asking a methodological 
question on how the GHG performance should be calculated. The methodological issues are separately discussed 
in Annex V.  
4.1 Further explanations of  the different options 
4.1.1 Policy options on sustainable production and management of ag ricultural and forest land  
Annex III outlines the voluntary actions already taken to ensure sustainable production of 
biomass in the forestry agriculture and waste s ectors. It gives an i ndication of progress and 
developments in the absence of new policy initiatives in this area.  
 
EN 17   EN Option A1 would be no new EU action.  
Option A2 (guidance) would have  the effect of developing sp ecific guidance at national or 
European level on dealing with the effects of  intensified forest management, including 
harvesting of branches and leaves and stum p harvesting. Today, these techniques are not 
common practice due to economic constraints and their impacts are not fully understood. 
Some Member States have issued preliminary guidance on the issue, (such as the UK's Forest 
Research Authority in April 200940). Intensified harvesting of th is kind could lead to lower 
amount of deadwood. The effects of a lower amount of deadwood depend on a number of 
factors, like the presence of saprophytic organisms41 or the types of soils. The lack of 
empirical data makes it difficult to predict th e impacts for different soil types. Intensified 
forest management can also have potential bene fits, such as the need for less intensive ground 
preparation and improvement in tree stability, as well as improved disease and pest control. It 
should be noted that option A2 would not es tablish mandatory "no-go areas" to protect 
biodiversity or to prev ent carbon-stock losses. 
For option A3 (criteria for 'no-go' biodiverse areas and land use change), it must also be 
considered whether the close link with other po licies, notably on sustai nability criteria for 
biofuels and bioliquids would cause any incons istencies for biomass producers. Extending the 
RES-Directive biodiversity and land-use criteria  to all biomass would at least ensure that 
biomass for all energy purposes are treated in the same way (even though inconsistencies may 
remain for non-energy uses). However, these w ould need to be adapted, as the no-go areas 
were developed with the purpose of avoiding unde sirable land conversion (usually to arable 
land).  
Option A4a (A3 + reporting biomass origin) requires that Member States register the origin of 
biomass used in electricity and heating and repo rt it to the Commission. This is so that the 
Commission can monitor the areas where biomass originates from to see if land use change 
has occurred in those areas. If problems are id entified in certain ar eas, the Commission would 
propose appropriate corrective action. Two op tions for further action are possible: a 
legislative proposal could addr ess the issue following monito ring of biomass origin, or 
appropriate corrective action coul d be included in the Directive covered by the present impact 
assessment. 
Option A4b (A3 + reporting on SFM) would re quire mandatory reporting on sustainable 
forest management. At EU level, the Pan-European Operational Level Guidelines for Sustainable Forest Management c ould serve as a basis for the ag reed principles and measures 
and reporting could be based on th e criteria and indi cators agreed by th e Lisbon Ministerial 
Conference on the Protection of Forests in Europe (although MCPFE  reporting has shown 
shortcomings on consistency and data adequacy)
42. However, as third countries cannot be 
required to report to the Commission, the Commission itself would need to monitor 
developments in third countries.  
Option A5 (A3 + SFM requirements) would requi re a common and precise definition of SFM. 
The definition used by the UN and MCPFE is: "the stewardship and use of forests and forest 
lands in a way, and at a rate, that maintain s their biodiversity, prod uctivity, regeneration 
                                                 
40 Forest Research (April 2009) Stump harvesting guidance, sited at: http://www.forestresearch.gov.uk  
41 Organisms that feed on dead organic matter, especially fungus or bacterium 
42 19 other non-EU states are members and report on this basis to MCPFE 
 
EN 18   EN capacity, vitality and their potential to fulfill, now and in the future, relevant ecological, 
economic and social functions, at local, nationa l, and global levels, and that does not cause 
damage to other ecosystems" . This definition is globally accepted but the principles and 
measures to implement this definition vary from  region to region and i ndicators and criteria 
are defined locally. It is theref ore not easy to find common thres holds and criteria that can be 
applied globally. Moreover, it may be difficult to enforce this option all over the world, in 
particular given the weak inter-government al responses identified in Annex IV.  
Furthermore, studies suggest that setting common rules for minimum rules for SFM are 
difficult, given the climatic differences and th e uncertainty about the impacts of harvesting 
intensity. Guidance has been issued by the IPCC for methods for estimating greenhouse gas 
emissions due to changes in biomass, dead organic matter and soil or ganic carbon on Forest 
Land and Land Converted to Forest Land. The relevant carbon pools and non-CO2 gases for 
which methods are provided for are: Biom ass (above-ground and below-ground biomass), 
dead organic matter (dead wood and litter), soil organic matter and non-CO2 gases (CH4, CO, 
N2O, NOX). However, there are uncertainties associated with  aggregated sampling levels, 
uncertainty of the level of residue production, of soil carbon43 etc and the guidelines apply to 
the preparation of national GHG inventories, and th ey are not readily app licable for use at the 
holding level.  
Therefore for Option A5, it is recommended to consider the following minimum criteria:  
1. Obligation on economic operator to ensure fore st regeneration is ta ken within x years. 
2. Obligations for measures in place to ensure viable population of forest-dependent species 
3. Obligation that forest biomass extraction mu st not result in large scale net losses of 
nutrients or acid buffering capacity 
4. Carbon stock of forests must remain at least balanced.  Option A6 (A3 + LULUCF accounting) would allow for all biomass which originates from 
countries which account carbon balances under LULUCF to count towards the renewable 
energy targets. Biomass which originates from countries that do not ac count would need to 
provide further evidence that the biomass comes from sustainable sources, as follows: 
SPECIFIC SITUATION: Î REQUIREMENT: 
Country of origin accounting under LULUCF No  requirement on operators (emissions from 
LULUCF are accounted at national level) 
Country of origin not accounting nor 
reporting under LULUCF (i) COM to introduce a specific emissions 
factor due to land use change in the GHG methodology at operator level, or 
(ii) COM to request alternative evidence on 
carbon stock balance at national level, or 
                                                 
43 Liski et al (2005) concluded that  estimates of the amount of soil car bon are uncertain by nature because 
they depend mostly on uncertain humus parameters 
 
EN 19   EN (iii) COM to request alternative evidence on 
carbon stock balance at operator level, or 
(iv) COM to monitor developments based on 
that reporting and to intervene if deficit/loss 
Negotiations on the future international rules for LULUCF accounting are currently on-going. 
Under the Kyoto Protocol Annex-I carbon emi ssions related to energy from biomass are 
counted as zero on the basis that emissions ar e reported in the LULUCF sector. Under Article 
3.3 of the Kyoto Protocol, Parties are obliged to account for afforestation, reforestation and 
deforestation activities ( obligatory accounting ). Under Article 3.4 of the Kyoto Protocol, 
Parties may choose to account for the following four activities: forest management, cropland 
management, grazing land management and revegetation ( optional accounting ). The method 
of accounting under existing accounting rules means that carbon emission reductions from the use of biomass are prone to overestimates.  
In order to address inter alia  this problem the EU is currently considering its position with 
respect to accounting options for forest ma nagement. Generally speaking, two preferred 
accounting options have emerged within th e EU (although severa l more are still under 
consideration in the UNFCCC negotia tions). First, a 'bar'-appro ach based on a reference level 
against which net emissions and removals ar e compared. Second, gross-net accounting with a 
discount factor where net emissions and remova ls from forest management occurring during 
the commitment period are discounted by a predeter mined factor in orde r to address LULUCF 
specific issues like scale effects and natural disturbances. The bar-app roach maintains full 
parity with non-LULUCF mitigation options a nd the gross-net accounting with a discount 
factor has the advantage that ne t removals lead to credits and net emissions to debit, however 
net emissions in the LULUCF sector are discount ed in comparison to emissions that occur in 
other sectors. This gives an a dditional incentive to the use of forests as a way to substitute 
fossil fuel rather than to sequester carbon. Over all the effective deliver y of the two options 
with respect to environmental integrity depends on the way they are implemented: e.g. the choice of discount factor and th e national reference levels.  
These options for LULUCF accounting would as such have no impact on the way biomass is 
accounted for the purposes of meeting renewabl e energy targets or for counting as zero-
carbon emissions under ETS. However, the Effo rt Sharing Decision requires that the 
Commission looks into whether the outcome of  the international negotiations on LULUCF 
provides sufficient guarantees fo r the accounting of emissions fr om forest management. Any 
action to redress the outcome of negotiations could reasonably be applied to forests in the EU. 
It would be more difficult to put  obligations on third country im ports of biomass. That is why 
the option of incorporating a LULUCF accounti ng system in a sustainability scheme for 
biomass is addressed here, in order to asse ss possible requirements that could allow the 
Community to intervene in cas e biomass production in certain countries would prove to be 
problematic from the perspective of  related emissions to land use.  
4.1.2. Policy options for ensuring GHG savings based on a life cycle approach  
The GHG methodology adopted under the RES Direct ive was designed for biofuels used in 
transport and bioliquids. Analysis suggests that  this methodology is also suitable for use for 
heating and electricity applications in general, with certain adaptations to allow for specificities of biomass use in heating and electricity. See Annex V for this analysis.  
 
EN 20   EN The RES Directive requires biofuels and bioliquids to meet a 35% minimum GHG 
requirement (35% 'threshold'). For biofuels, the ex tent of the savings (in percentage terms) is 
determined through comparison with the emissions from the fossil part of petrol and diesel 
consumed in the Community (fossil fuel comparator). 
Putting in place comparable minimum requirements for GHG performance would be desirable 
(a) for biomass pathways which risk not ach ieving significant GHG emissions over the life 
cycle and/ or (b) to create general awareness of the GHG performance of products in general.  
When setting minimum GHG requirements for bi o-electricity and bio-heat pathways, the 
additional compliance cost of economic operators should be weighed up against the additional benefits in terms of GHG savings. It could be argued that as forest biomass delivers a significant GHG saving over the life cycle when us ed in electricity and heating applications 
(usually above 80% savings as compared to aver age EU fossil heat or electricity), it would 
introduce unnecessary admini strative burden to prove the GHG savings achieved.  
As most of the biomass used in electricity a nd heating is based on solid and gaseous biomass 
coming either from the forest or from agricult ural residues (e.g. tree br anches and straw) and 
processing residues (e.g. pellets from saw-dust), a business as usual policy scenario outlined 
in Option B1 (no new EU action) and B2 (lab elling) would not require the introduction of 
minimum GHG performance requirements. Howe ver Option B2 would enable consumers to 
know the GHG performance of electricity and hea ting plants. As most of the emissions occur 
in the production and conversion phase, (not in  the processing phase as  with biofuels) there 
are less risks from not having a GHG  minimum performance requirement. 
Option B3 (minimum GHG savings for agriculture and forest biomass) would ensure that the 
same minimum requirements apply to all biomass
44 used for energy purposes. This would 
ensure consistency for feedstocks that can be us ed both in transport (biofuels) or electricity 
and heat. Having the same threshold for all e nd uses would also avoid calculation problems 
when allocating GHG emissions to heat and electr icity or biofuels in a cogeneration or tri-
generation plant45. On the other hand, the number of possible pathways could make this an 
overly complicated system and proxies may need  to be developed with generic values for 
similar feedstocks and processes, such as dige stion of energy crops having one value (e.g. for 
maize, rye etc.) or all energy grasses having one value etc.  
Option B4 (minimum threshold based on best-pra ctice) would ensure that best practice is 
followed, as all biomass has the potential to improve GHG savings by ut ilising best practices. 
However the same methodological questions  as under Option B3 would remain.  
4.1.3. Policy options to promote efficient res ource use by increasing energy conversion 
efficiency 
This issue looks only at the end of the bio-energy chain, and does not tackle resource 
management, therefore only cons iders one factor in a life-cycle assessment, the energy 
conversion efficiency. Therefore the options on energy efficiency  can be consid ered together 
with the options under production and GHG performance.  
                                                 
44 Short rotation coppicing and plantations, such as palm are included in the consideration of agricultural 
biomass. 
45 Second generation biofuels have  a minimum GHG requirement becau se they also count for the 
purposes of the Fuel Quality Directive 2009/30/EC. 
 
EN 21   EN The end-conversion of biomass to electricity and/or heat is generally influenced by the 
objectives and technical constraints of the end- user. Therefore it is relevant to understand 
which type of stakeholder is involved, and wh at technical opportunities and constrains for 
improvements exist.  
Residential use : Small-scale boilers are generally used  by households for heating purposes. 
These are considered outside of the scope of  this impact assessment because Community 
legislation on energy efficiency and further environmental aspects, including particulate 
matter emissions, is currently under developmen t for (mainly) residential boilers, including 
boilers fired by liquid, gaseous or solid biofuels, under  
– the Eco-design for energy-using products directive 2005/32/EC, 
– the Energy labelling directive 92/75/EEC, 
– the recast of the Energy labelling di rective proposed by the Commission end 
2008, COM(2008)778, in particular Arti cle 9 on public procurement and 
incentives, 
– the recast of the Energy performance of  buildings direc tive proposed by the 
Commission end 2008, COM(2008)780, in pa rticular Article  8 related to 
minimum energy performance requirement s of technical building systems. 
These policies are expected to improve the c onversion efficiency of (mainly) residential 
boilers to a satisfactory extent, and no additional action is required for residential boilers46. 
Three other characteristic stak eholder groups are relevant to distinguish for the purposes of 
this impact assessment: 
Utility companies  - Large companies (above 1MW capacity ) produce electricity and/or heat 
from biomass through co-firing or large stand-al one installations. Their incentives are national 
support schemes and/ or the emission ceiling of the emissions trading scheme (ETS). They usually source their biomass over large distances a nd respond rapidly to pr ice changes. It is a 
small and well-informed stakeholder group, often acting because of available support 
schemes. 
Small commercial producers (below 1MW capacity)
 – These companies are not historically 
involved in electricity and/or heat production and th ey operate one or several stand-alone 
installations that produc e heat and/or electricity from bi omass. Their incentive comes from 
national support schemes or the local availability of affordable biomass. It is a small and well-
informed stakeholder group, usually acting becaus e of available subsidies. Biomass costs are 
a substantial part of their operations costs. 
Industry  - Some industries produce biomass by-products  that they use to supply electricity 
and/or heat for their own proces ses. Their incentive is the availability of a cheap energy 
source that needs disposing of when not used, e.g. paper & pulp  industry, sugar industry with 
bagasse surplus, saw mills with wood chips boilers. Support schemes for renewable energy 
production are usually not a motivation, though reducing the overall GHG emission can play 
a role. 
                                                 
46 Link to website of preparatory studies: www.ecoboiler.org , www.ecosolidfuel.org  
 
EN 22   EN Depending on the user, diffe rent policy measures could be considered as effective or efficient 
in promoting higher energy conversion efficiency.  
Option C1 (no new EU action) w ould continue to rely on existi ng policy tools such as the 
Cogeneration Directive47 which sets benchmarks for high- efficiency cogeneration plants. 
Member States have also adopted national policies to improve energy efficiency (e.g. 
included in feed-in tariff, energy efficiency obl igations), but few Member States currently 
explicitly consider the end-conversion of  biomass installations in their policy. 
Option C2 (bonus/ penalty) allows the economi c operator to make the decision on the 
investment in the bio-energy installation to bene fit from a bonus or to avoid a penalty. This 
can make investment in more expensive options  more cost effective. If the incentive is 
sufficiently high, the economic operator will res pond by shifting to more efficient options. If 
inefficient processes do not count  towards targets, Member St ates are likely to respond by 
adapting their support schemes to ensure that only those bio-energy options are supported that 
really count for their national target. The penalty  therefore has to be high in order to make a 
difference. However, Member States would be free to set the level of  the bonus/ penalty and 
would be able to choose which efficient technologies to incentiv ise according to  their national 
conditions and to respect subsidiarity. 
Option C3 (minimum efficiency requirements)  would exclude the a pplication of certain 
biomass pathways or installations, but the decisi on not to use this pathway or installation does 
not depend on an economic calculation of th e economic operator but is made by the 
government. Its effects can reach beyond support sche mes, and in principle be applicable to 
all biomass conversion installation. If commonl y used technology is banned, there is a risk 
that economic operators will make a different  economic calculation on the use of biomass. 
This would be undesirable, especially in t hose cases where residue streams with no other 
purpose (like manure) are being used for en ergy production. However, this risk may be 
eliminated if only the worst-performing technologies are banned. 
Option C4 (labelling) would create awareness,  appealing to the envi ronmentally conscious 
and highlight cost saving through more efficient biomass use. It does not exclude the use of 
inefficient pathways or installati ons, nor does it create a financial incentive to take this aspect 
into account. Therefore,  the labelling of end conversion e fficiency on installations is only 
relevant for consumer goods, when the creation of awareness can influence the decision making. Its relevance is small for commercially  operating installations, as feedstock costs 
(directly related to efficiency) are a primary el ement of the cost calculations. So the policy 
option is most suitable for residential boile rs which are not covered by this impact 
assessment. 
Option C5 (improve supply chain efficiency ) would only stimulate higher end-conversion 
efficiency if the inefficient biomass plant in  question is compared to an average or high 
efficiency fossil alternative over the life cycle. The effectiveness of this option in effect comes 
down to the design of the GHG calculation method for the whole chain and improving 
efficiency is limited. 
Options to be discarded:
  
                                                 
47 Directive 2004/8/EC 
 
EN 23   EN The policy options have been screened for e ffectiveness, efficiency and consistency.  
Option A2 is discarded because the science is not yet well developed to be able to develop 
guidelines at EU level on some  issues such as stump ha rvesting. The UK and Swedish 
guidance indicate that even within one Member  State, the removal of  stumps would have 
different effects on differe nt types of soils. Other practices such as removal of branches and 
tops are better understood but their effects vary  locally. Reviewing data on harvesting forest 
residues, the Commission (JRC) observes that the impacts of more intense harvesting are 
small. This is partly because ha rvested forests absorb carbon dioxi de faster than mature forest 
stands, so harvesting them for energy use increases the CO2 uptake from the atmosphere (Liski et al 2005
48). The development of such guidance is more effective when left to Member 
States. 
Option A4b is discarded because reporting would not give additional benefits in terms of 
ensuring sustainable forest management. This is because there are la rge differences between 
countries in criteria and more pa rticularly in the indi cators used to eval uate progress, even 
within Member States. Results of the FORSEE project49 showed that sustainability 
assessment at local level offers the possibility of adapting forest management and improving forest operations. Monitoring of sustainable forest management at EU level would therefore 
be impossible unless common reporting requirements/  criteria were set. Another issue is that 
reporting based on MCPFE criteria and indicators could not be exte nded to third countries, as 
third countries have agreed to different crit eria and indicators for reporting under other 
intergovernmental initiatives. 
Option A6 is discarded because LULUCF accoun ting addresses the problems of accounting
50 
for biomass emissions and not the problem of ba d practices as regards unsustainable forest 
management. The problem of balancing carbon stoc ks is not unique to th e energy sector and 
is not the problem identified in section 2 of  the impact assessment. All activities on land, 
including production systems for food, feed and fibre have an impact on carbon emissions and 
removals from LULUCF. It is therefore not appropriate to simply look at emissions and 
removals from the LULUCF sector from a pure bi o-energy sustainability perspective, as this 
can provide only a partial policy response to ma ke the LULUCF sector contribute to climate 
mitigation. Instead a comprehensive framewor k may be needed to address the complex 
interactions between activities  in the sector. More importan tly, the accounting has not yet 
been agreed on, so it is not clear how carbon from forests would be accounted. 
                                                 
48 If the felling residues and thinnings are left in the fo rest, they initially add to the stock of carbon in the 
forest litter, but they rot away w ith a characteristic exp onential decay time of about 10 years and the 
balance of carbon emissions from using forest residues turns positive after 3 to 7 years. Removing 
residues also removes some fixed nitrogen from th e forest, and replacing with artificial fertiliser would 
generate N2O emissions in the forest soils at about the same magnitude as those from the decomposition of the forest residues. 
49 FORSEE "Sustainable management of forests: a European network of pilot zones for putting this into 
operational effect", information at: http://www.iefc.net/index.php?affiche_page=project_FORSEE   
50 The combustion of biomass involves GHG emissions, but it is considered carbon-neutral following the 
practice of the IPCC national inventory guidelines, where emissions from biomass are included in the 
energy sector for information only, and not added to th e total. The reason for this is that emissions from 
combustion are offset against CO2 absorbed from the atmosphere during the growing phase. In 
addition, any changes in the carbon stock on land ar e reported under the land use, land-use change and 
forestry category, therefore counting them un der energy would constitute double counting. 
 
EN 24   EN Option C4 is discarded because the policy option of labelling of end-conversion efficiency is 
mostly relevant during the sales period, which is  not relevant for large scale electricity or 
heating installations. 
Option C5 is discarded because the effectivenes s for improving the end-conversion efficiency 
is limited. This does not mean however that conv ersion to electricity an d heat should not be 
part of the methodology. It is si mply considered that it is not a tool for incentivising higher 
end-conversion efficiency. This issue is  further elaborated upon in Annex V. 
Section 5: Analysis of impacts 
In deciding whether or not to in clude a particular type of imp act, the findings of the Impact 
Assessment for the development of the sustainabili ty criteria for biofuels  and bioliquids were 
observed51. That assessment found that: 
– it should be feasible to associate impacts with individual consignments of biomass 
and to associated negative impacts with biomass production.  
– international law aspects should be observed. 
– the cultivation of agricultural crops fo r different purposes (including biofuel 
production) can cause substantial environmental damage if this cultivation takes place on inappropriate land. 
– biomass consignments are not easily associated  directly with social impacts, such as 
respect for fundamental human rights or land rights associated with production 
This impact assessment explores the following ma in effects of the policy options for biomass 
promotion: 
1. environmental impacts 2. economic impacts  
– economic availability of biomass 
– costs to economic operators 
– costs to public administration 
3. social impacts 
– employment 
– households 
5.1. Policy option to foster su stainable biomass production  
As set out in section 4, four options were retained for assessment: 
                                                
 
51 SEC(2008)85 
 
EN 25   EN Option A1: no new EU action 
Option A3: criteria on biodiversity and land use  
Option A4a: Option A3 + rep orting on biomass origin 
Option A5: Option A3 + SFM minimum obligations 
When considering the impacts of the policy options for production, it must  be considered that 
producers will come from both EU and non-EU. Currently the import of wood and wood waste for energy purposes, from outsi de the EU is around 3 Mtoe, or 3%
52, mainly imported 
in the form of pellets53. As a consequence, the impacts of introducing sustainability criteria 
will largely fall on EU biomass producers. 
5.1.1 Environmental impacts A sustainability scheme at EU level should ensure that biomass supported in the EU is 
coming from sustainable production irrespective  of its origin. The RES Directive requires 
Member States to ensure that economic operators can prove where the biomass originates from and that the biomass used does not come  from highly bio-diverse or converted high-
carbon stock land. 
a. Biodiversity  
To avoid the use of land with high biodiversity  value for the production of biofuels, Article 
17(3) of the RES-Directive has identified different types of la nds that are considered highly 
biodiverse: 
– primary forests and other w ooded land of native species where there is no clearly 
visible indication of human activity and the ecological processes are not disturbed 
– areas designated by law or by the relevant competent aut hority for nature protection 
purposes, or areas designated for the prot ection of rare, threat ened or endangered 
species recognised by intern ational agreements or in cluded in lists drawn up by 
intergovernmental orga nisations or IUCN 
– highly bio-diverse grasslands  (natural and non-natural). 
Option A1 (no new EU action) would not afford  any minimum protection for biodiversity and 
would not prevent negative environmental impacts.  
All other options (Options A 3, A4a and A5) extend the above (RES-Directive) biodiversity 
criteria to all biomass used for energy purposes , with the premise that some exceptions for 
forest biomass could be made, as follows:  
                                                
 
52 Eurostat 2007 data 
53 The European Biomass Association (AEBIOM) estimates that by 2020 up to 80 million tons of pellets 
could be used in the EU (33 Mtoe), http://www.aebiom.org/IMG/pdf/Pellet_Roadmap_final.pdf 
 
EN 26   EN First, stakeholders said that there are instan ces where primary forests or protected areas are 
subject to natural disasters, where trees are felled or are degrading54. In this case the best 
option may be to use a share of the trees for en ergy or other purposes in stead of leaving them 
in the forest to degrade.  
Second, stakeholders argued that biodiversity cr iteria may lead to the value of timber from 
bio-diverse forests to be devalued an d that owners should be compensated.  
The first exception for forest biomass could be  justified on environmental grounds where the 
need for deadwood for soil quality and mainte nance of biodiversity are also taken into 
account. However the essence of primary forest s is that they are undisturbed by man and 
deserve to remain protected from human interf erence even if they are subject to a natural 
disaster. In fact, the presence of natural disturbance regime s and the resulting dead and 
decomposing organic matter is th e key attribute of such forest systems, and the main reason 
for their protection. The sec ond exception is based on economic arguments and may no longer 
lead to the environmental protection that is deemed to be necessary for preserving ecosystems. Therefore neither the first nor the second exceptions are accepted.  
b. Land use change In the RES Directive, some high carbon stock lands cannot be converted for the use of 
biomass for energy purposes, as the loss of carb on could never result in the biofuel meeting a 
GHG threshold value. These areas are:  
– wetlands  
– forested areas with canopy cover of 30% or more 
Option A1 (no new EU action) would not affo rd any minimum protection for conversion of 
high carbon stock areas. 
Options A3, A4a, A5 all extend the land use criteria to all biomass. Moreover, GHG 
emissions from the conversion of land are al so included in the proposed calculation of 
greenhouse gas emissions (see Annex V). Stakehol ders in the public consultation pointed out 
that when converting forests, forest biomass ca n still count towards th e target, even if the 
forest will not be regenerated,  as at the time of conversion it  was not yet known if the trees 
will be regenerated or not. Stakeholders also pointed out that the definition of continuously 
forested areas may need to be refined to avoid that natural forests
55 can be converted to 
plantations without any pena lty for land use change.  
To avoid negative land conversion of high carbon st ock areas, it would be necessary that at 
least the land use criteria set in the RES Directive on land us e should apply (as proposed by 
Option A3).  
It should be considered whether further r eaching requirements are needed to protect 
biodiversity and avoid negative land use change . Option A3 does not 'guarantee' that forest 
carbon balances remain neutral in the long term  or that sustainable forest management 
                                                 
54 This is the case of Canada, where [x] hectares of  primary forest are destroyed due to pine beetle 
infestation. 
55 A forest composed of indigenous trees and not classified as forest plantations 
 
EN 27   EN principles are applied in produc tion of biomass. Options A4a and A5 would go further to 
monitor areas where the biomass comes from or for promoting sustainable forest management.  
Option A4a would have the added benefit of co llecting information on the origin of all the 
biomass used for heating and electricity purpos es in the EU. This would give a tool for 
monitoring those areas where the biomass comes from, and a basis for corrective action to be 
taken in respect of regions if the monitoring fi nds that forests are not regenerating in certain 
regions.  
Option A5 would go further th an reporting and require mini mum requirements for SFM. 
Historically, it has been difficult to agree common SFM standards gl obally. Four possible 
minimum requirements (as identified in section 4) are considered.  
1) A requirement for economic op erators to ensure forest regeneration is taken within a 
certain number of years  would create an obligation on economic operators to plan for 
regeneration activities. Forest law in most EU  Member States alrea dy requires regeneration 
following harvesting. However, if the economic operator in the EU imports from countries which do not have such requirements, it is impossible to get such a guarantee, unless the 
economic operator enters into a contract with  forest owners. It would be difficult for a 
Member State to know whether forest bioma ss can necessarily be counted towards the 
renewable energy targets, as at the time of using the biomass for energy production there is 
often no way of knowing whether the forest ar ea where the biomass came from will be 
regenerated. 
2) A requirement for measures in place to ensure viable population of forest-dependent 
species  is difficult to define, as for each region there would need to be a list drawn up of 
forest-dependent species and the quantity or am ount of a viable population would need to be 
defined. An alternative therefore is to draw up lists of areas for th e protection of rare, 
threatened or endangered eco-systems or species . This is made possibl e under the bi odiversity 
requirements in the Renewable Energy Directive,  where such lists can be approved through a 
comitology procedure. It would th erefore be achieved under Option A3. 
3) A requirement for forest biomass extractio n not to result in large scale net losses of 
nutrients or acid buffering capacity  is also difficult to define globally, as the amounts of 
nutrients or scale of buffering w ould differ from region to region.  
4) A requirement that the carbon balance of  forest must remain at least balanced  is a possible 
way forward. However, first stock needs to be taken of the carbon balance of each forest area 
or region. This is scientifically challenging as common measurement me thods would need to 
be developed. Furthermore, such a require ment would also no longer only focus on the 
sustainability of the energy use of biomass, but  would in effect introduce a stable land use 
requirement, so that all forests which are currently forests must remain forests. It remains to 
be seen whether international climate negotiations and intern ational initiatives on SFM can 
lead to minimum requirements that can be applied to all forests.  
In sum, verification of SFM at EU or global level would be impossible without setting 
common requirements. On the other hand, it is commonly accepted that SFM certification 
standards should not be consider ed as cast-iron measures of sustainability but as evolving 
tools in an adaptive management system w ith the ultimate aim of sustainability.  For all these 
 
EN 28   EN reasons, it would be undesirable to set mini mum sustainability standards for forest 
management specifically for energy purposes.  
Option A4a goes furthest in terms of environmental protection bearing in mind the 
impracticalities of Option A5. Option A4a en sures minimum protection of biodiverse and 
high carbon stock areas and provides a tool for collecting the necessary information on 
biomass origin to enable monitoring of biomass producing areas.  
5.1.2. Economic impacts a. Costs to public administration The basic cost for public administrations to implement Options A3, A4a and A5 are assumed 
to be similar as authorities in each case would n eed to verify at least the origin of biomass i.e. 
the chain of custody. Using the EU's Sta ndard Cost Model, the COWI Consortium 
distinguished between one-off and recurring cost s. It was estimated that one-off costs are 
larger than recurring costs, based on the assump tion that most of the resources are needed for 
the transposition of new legislation. One-off costs are calculated to be between €0.3-1.1 
million (low cost and high costs respectively
56) and recurring costs between €0.1-0.2 million 
per year for the EU-27. The recurring costs include the cost of the annual reporting 
requirements under Option A4a to the Commission.  
Under Option A5, additional costs may be incu rred depending on the minimum requirements 
for SFM. If forest vitality would be a mini mum requirement, more expensive verification 
tools may be needed, requiring that  the land is phys ically inspected. 
It also has to be considered whether it is f easible to require Member States to verify 
compliance of household consumption of bioma ss. Households mainly use wood for heating 
purposes and often they procure wood from sm all local suppliers. Al though the household-use 
of biomass is significant, it is considered th at it would be burdensome to require households 
to verify the origin of the wood. Member States  should therefore be responsible for regulating 
and monitoring household biomass use. Monito ring could be done by means of household 
surveys.  
Surveys can be costly. The World Bank57 estimated that specialised household energy surveys 
cost between US$50,000-150,000. Cost factors includ e sample and questionnaire size, local 
per diem, and salaries. Eurostat is collectin g information on househol ds via the European 
Union Statistics on Income and Living Cond itions and the Household Budget Survey. 
Member States contribute to these surveys voluntarily. Many Member  States also have 
existing household surveys to whic h questions related to biomass use could be added. In this 
way survey costs could be minimised. 
b. Cost to economic operators The estimated administrative costs to the ec onomic operators under Options A3 and A4a are 
assumed to be similar. To estimate the cost of providing proof of the origin of biomass 
                                                
 
56 The difference between low and high scenarios correspond to differences in the average EU wages for 
legislators and clerks 
57 O'Sullivan K., Barnes D. (2006) "Energy Policie s and multi-topic household surveys ", The World 
Bank 
 
EN 29   EN through chain of custody (CoC) certification, under  Options A3 and A4a, existing schemes in 
Europe were studied.  
In Belgium, electricity producer s are required to prove the sust ainable character of forestry 
resources in order to receive green certificates . Electrabel for instance, uses SGS Belgium as 
an independent body to check the biomass s upply chain data based on a certification 
procedure designed jointly by Electrabel and Research Centre Laborelec. Evidence is 
delivered according to a traceable chain of custody system and forest management certification or public document s originating from independent bodies such as FAO or NGOs 
who make a review of the forest management  and control in the considered country. The 
proof then is supplied in the form of a "Bio mass Supplier Declaration", which is 6 pages, 
consisting of declaration of the wood orig in, the production chai n, including energy 
consumption, and transportation and storage. Since 2003, 75 suppliers have been audited, including in Brazil, South Af rica, Malaysia and North Am erica (SGS Presentation, EU 
Sustainable Energy Week 2009). According to La borelec, the certification cost is about 0,5 
€/ton. 
The costs of implementing Option A5 could be much higher, as on top of CoC certification, a 
sustainable forest management (SFM) certif ication is also required. The BTG 2008 report 
estimates that that direct costs in Finland, Sweden, Germany and Norway can vary between 
0.01-€0.79/ha/year (excluding indire ct costs). This is equivalent to around €0.01-0.38/ ton
58 
and these costs were estimated for larger fore st holdings (forest holdings of 10,000 – 2 million 
ha). For small private forests, the cost per can  go up to €6/ha/yr for a 100 ha forest holding, or 
about €12.6/ ton59. The main difference between costs is du e to the size of the certified area. 
The estimated cost for SFM certification (Opt ion A5) was assessed by the COWI Consortium 
(2009) using the EU's Standard  Cost Model. They looked at costs for biomass producers, 
processing and manufacturing industr y and traders as well as ener gy producers. One-off costs 
and recurring costs were distinguished. It was found that the recurring costs of running SFM 
certification systems, i.e. surveillance and reasse ssment audits, can be as costly as the initial 
certification for SFM60. Assuming that all biomass producers in the EU would need to be 
certified, the COWI Consortium estimated one-o ff costs for biomass producers in the EU-27 
to be between €0.2-6.7 million and recurring co sts €3.3-38.4 million per year. For individual 
biomass producers this could amount to  recurring costs of €2,000 - 24,000 per year61. In 
contrast, recurring chain of custody certification costs (under Options A3 and A4) were 
estimated to be between €800-3,000 per year  for individual biomass producers.  
c. Economic availability of biomass The COWI Consortium (2009) a ssessed whether sustainability  criteria on land use and 
biodiversity (as in Options A3, A4a and A5) w ould have any impact on economic availability 
                                                
 
58 Based on 3m3/ha and 0.7 tonne/m3 
59 Even the 100 ha average holding could still be cons idered large in overall EU  terms. The EU average 
holding is about 10 Ha but many Member States have  millions of much smalle r units. In Greece, forest 
ownerships are measured in Stremmae (0.1 Ha). 
60 The COWI Consortium distinguished between potential costs of FSC-type SFM certification and the 
Green Gold Label (GGL) type SFM certification. FSC  certification generally implies costs 2.5 times 
higher than those related to the GGL approach.  
61 At the individual operator level, the costs are highest for biomass producers. One-off costs can be up to 
25 times higher than for other economic operators, while recurring costs can be 5-10 times higher. 
 
EN 30   EN of biomass. The scenarios from the consulted l iterature, that take in to account a number of 
uncertainties and sustainability constraints, lead to a global biomass potential of 200-500 
EJ/year in the longer term (2050-2100). 
Forestry residues:  Green-X projects imports of forestry residues of around 9 Mtoe. In a study 
by the EEA62, no specific attention is paid to sustaina bility issues related to these imports. The 
IEA Bioenergy review63 analysed global biomass availability and mentions a potential of 
forest residues of 30-150 EJ (700-3600 Mtoe) by 2050, of which a major share would become 
available in the coming one or two decades. Howe ver, these indications do not explicitly take 
into account any land exclusion criteria. It may be clear that not all forest import materials 
currently available will meet the land exclusi on criteria as laid down in the RES Directive. 
Given the ratio between projec ted availability and the 9 Mt oe projected in GREEN-X by 
2020, it could be concluded that ther e will be sufficient forestry  material available for import 
that does meet the land exclusi on criteria. Even if imports of pellets projected to be 33 Mtoe 
by AEBIOM are realised, this is still a small share of the ava ilable range identified above.  
Agricultural crops : Biofuels and bioliquids are al ready covered by the land use and 
biodiversity criteria laid down in the RES-Directive. GREEN-X assumed that 30% of biofuels 
consumption will be met by ex-EU imports, mainly consisting of vegetable oils (rape seed, soy and palm oil) and bioethanol. At a 10% biofuels share in 2020, total imports would add 
up to almost 10 Mtoe, of which 3 Mtoe rapese ed, 2 Mtoe soy, 2 Mtoe palm and 2,5 Mtoe 
bioethanol. The IEA Bioenergy Review projects a production pot ential for energy crops of 0-
700 EJ, with a moderate estimation of 120 EJ (or almost 3000 Mtoe) by 2050.  
As the underlying studies for this assessment usually limit their analysis to currently available 
agricultural lands (see e.g. the detailed review by Dornburg et al, 2008
64), it is expected that 
the lion’s share of this potential will meet the land exclusion criteria. The share that can 
become available by 2020 is not further specifi ed. Again, it should be stressed that these 
availability estimations strongl y depend on developments in ag ricultural productivity, animal 
husbandry and food consumption. However, the curre nt global trade volum es of palm and soy 
(ca 25 Mtoe and 10 Mtoe, respectively65), are substantially larger  than 2020 demand for these 
sources. Therefore, it seems reasonable that this  demand can be met by oils that meet the land 
exclusion criteria, provided a verifi cation system is put in place. 
5.1.3. Social impacts It is presumed that there will be no impact on households (if they are exempted from the 
requirements) and on employme nt. Employment opportunities would arise under Option A5, 
as not only biomass origin but also the sustaina ble management of forests would need to be 
                                                
 
62 EEA (2007a): Environmentally compatible bio-energy  potential from European forests. Copenhagen, 
European Environment Agency 
63 IEA (2009): Bioenergy - A review of status and prospects. Paris, Bioenergy Agreement of the 
International Energy Agency 
64 Dornburg V., A. Faaij, P. Verweij, H. Langeveld,  G. van de Ven, F. Wester, H. van Keulen, K. van 
Diepen, M. Meeusen, M. Banse, J. Ros, D. van Vuuren, G.J. van den Born, M. van Oorschot, F. Smout, 
J. van Vliet, H. Aiking, M. Londo, H. Mozaffarian, K. Smekens, E. Lysen (ed.) and S. van Egmond 
(ed.) (2008): Assessment of global biomass portentials and their links to good, water, biodiversity, energy demand and economy. Bilthoven, MNP. 
65 Thoenes, P. (2006): Biofuels and Commodity Markets – Palm Oil Focus. Rome, United Nations Food 
and Agriculture Organisation 
 
EN 31   EN verified. However this option is also associated  with higher costs for administrations and for 
economic operators.  
5.1.4. Impacts on third country actors The countries most affected by setting GHG crit eria are those that already export solid 
biomass to the EU. Although it is difficult to obt ain information about biomass traded, some 
assessments suggest that most of Europe's im ports come from Canada and Russia, and to a 
lesser extent from Switzerland, USA, South Africa, Norway and Ukraine.
66  
The total administrative costs associated with complying with these options are difficult to 
quantify as the number of actors who may be a ffected is highly uncertain. It is however 
possible to assume that the administrative cost s per economic operator wi ll be similar to those 
calculated for EU actors, as outlined in section 5.1.2.b.  
5.1.4. Summary of impacts  
Table 2: Assessment of impacts of options to foster sustainable biomass production 
 Costs to 
public 
administrati
on (EU-27) Economic 
availability 
of biomass Costs to 
economic 
operators  Environmental 
impacts 
Biodiversity and 
Land use  Employment Households 
A. Production    
Option A1: no 
new EU action 0 
No effect 0 
No effect 0 
No effect 0 
Does not minimise 
risk of loss of 
biodiverse or high 
carbon stock land  0 
No effect 0 
No effect 
Option A3: criteria on biodiversity 
and land use - 
Some costs 
due to 
verifying 
claims on 
biomass 
origin and 
household 
surveys 0 
No effect - 
Proof of 
origin of 
biomass 
will incur 
some costs 
in 
developing 
tracing 
mechanism
s + 
Protection for highly 
bio-diverse and high 
carbon-stock areas  
 0 
No effect 0 
No effect 
Option A4a: 
Option A3 + mandatory 
reporting on 
biomass origin  - 
Some cost 
due to 
verifying 
claims on 
biomass 
origin, 
household 
surveys and 
formalising 
reporting on 
SFM 0 
No effect - 
Proof of 
origin of 
biomass 
incurs costs 
in 
developing 
tracing 
mechanism
s + 
Protection of highly 
biodiverse and high 
carbon stock areas  0 
No effect 0 
No effect 
                                                 
66 http://eubionet2.ohoi.net/ACFiles/Download.asp?recID=4705 
 
EN 32   EN  Costs to 
public 
administrati
on (EU-27) Economic 
availability 
of biomass Costs to 
economic 
operators  Environmental 
impacts 
Biodiversity and 
Land use  Employment Households 
Option A5: 
Option A3 + 
SFM obligation -- 
Costs of 
setting up 
verification 
tools 0 
No effect -- 
Increased 
certification 
or auditing 
cost  ++ 
Protection of highly 
biodiverse and high 
carbon stock areas 
and promotes SFM + 
Additional 
jobs for 
certification 
and 
verification 0 
No effect 
Table 2 shows that Option A1 does not minimise negative environmental impacts. An 
argument in support of Option A1 however is th at sustainable forest management is not 
specifically energy related and may be better tackled under current land management tools 
whether at national or EU level. Options A3 a nd A4a have similar environmental impacts, as 
reporting requirements are no t able to serve as a precautionar y measure to ensure that forest 
areas will be regenerated after harvesting, nor that forests will be  managed in a way to ensure 
the long-term production of forests. Option A5  would have additional positive impacts on 
biodiversity and land use, but has much higher costs to pub lic authorities and economic 
operators. Options A3 and A4a can be achieved at a reasonably low cost , given that Member 
States are obliged under the RE S Directive to develop verifi cation methods for determining 
the origin of biomass used to produce biofue ls and bioliquids. No significant impacts are 
expected on households or on employment, and the economic availability of biomass is not 
likely to be affected under Options A1, A3, A4a and A5. Th is is because the estimated 
economic potentials of biomass in 2020 alre ady exclude highly biodiverse areas.  
5.2. Policy options to ensure gr eenhouse gas emissions savings 
As set out in section 4, four options were retained for assessment: 
Option B1: no new EU action 
Option B2: labelling of GHG savings 
Option B3: minimum GHG savings for agricultural and forestry biomass (minimum 35%, increasing to 
50-60% in 2017/2018, as compared to fossil alternative)  
Option B4: minimum GHG savings in accordance with GHG saving potential (except for waste biomass) 
Greenhouse gas methodology  
In order to measure the greenhouse gas imp acts of bioenergy pathways, a methodology is 
needed to calculate GHG emissions incurred th rough the use of biomass in electricity and 
heating.  
In recent years a wide range of methods of measuring the greenhouse gas impacts of fuels 
have been devised. Differences in method have  sometimes led to sign ificant divergence in 
results. In designing the greenhouse gas me thodology used in the RES Directive, the 
Commission brought together repr esentatives of the biofuels and agricultural sectors with 
JRC, CONCAWE and EUCAR to work intensiv ely on the methodological issues (as well as 
data improvements). The methodology agreed wa s to take into account greenhouse gas 
emissions throughout the processes of production and use of fuels, including the effects of 
land use change.  
 
EN 33   EN It is proposed to build on the existing methodology in the RES Dir ective, but as "final energy" 
in the case of biomass implies heat or electric ity, it is possible to extend the scope to include 
conversion. In this way, it would be possible to  determine the GHG performance of heat and 
power uses of biomass.  
The proposed methodology thus follows life cycle principles, by calculating emissions from 
"cradle to final energy", including end conversio n efficiency for larger  energy facilities.  
If minimum emissions savings are to be agr eed, it is proposed to compare the GHG emissions 
to the emissions of the average fossil fuel plant at EU level. EU-wide fi gures are chosen since 
a distinction between e.g. Member States, would imply that some biomass is sustainable in 
some countries and not in others, which makes biomass trade overly complicated.  
Annex V gives further details about the proposed methodology.  
5.2.1. Environmental impacts To establish the greenhouse ga s performance from solid and gaseous biomass used in 
electricity and heating, the Joint Research Cent re (JRC) was asked to develop pathways for 
several different uses of biom ass, e.g. pellets, charcoal et c., these emissions are then 
compared to the average greenhouse gas emissions in the EU from electricity and heating in 
the EU. Annex VII includes the disaggregated emission values for solid and gaseous biomass 
pathways (calculated using JRC data, 2009), and some of the key assumptions used for the 
calculations.  
Graph 1 gives typical values for greenhouse gas savings for selected solid and gaseous 
biomass chains, including biogas, wood chips a nd pellets used in electricity and heating
67 
(losses for energy conversion are included,  based on assumptions of 25% electrical 
conversion efficiency, and 85% th ermal conversion efficiency).  
                                                 
67 Source JRC, 2009 [Typical values can be estima ted at the mid-points of ranges, but it cannot be 
excluded that production proc esses are sometimes worse than these typical values.] 
 
EN 34   EN Graph 1: GHG savings potential of solid biomass used in electricity and heating 
GHG savings from solid biomass used in electricity and heating
0%10%20%30%40%50%60%70%80%90%100%
FR chips (EU)
FR chips (tropical)
FR pellets (EU/wood process fuel) 
FR pellets (EU NG process fuel) 
FR pellets (tropical/wood process fuel)
FR pellets (tropical/NG process fuel)
FR charcoal (EU)
FR charcoal (tropical)
wheat straw (EU)
Bagasse briquettes (wood process fuel)
Bagasse briquettes (NG process fuel)
Bagasse bales
Palm kernel shells
Miscanthus
SRC chips (EU)
SRC chips (tropical)
SRC pellets (EU/ wood process fuel)
SRC pellets (EU/ NG as process fuel)
SRC pellets (tropical/ wood process fuel)
SRC pellets (tropical/ NG as process fuel)
solid biomass feedstocksGHG savings % 
(compared to EU fossil fuel)Electricity
Heat
 
*SRC refers to short rotation coppi cing and FR to forest residues 
The GHG savings in almost all cases are significant compared to the EU average fossil 
alternatives. This indicates that production of  bio-energy from solid biomass and from biogas 
typically delivers significant gr eenhouse gas savings (compared to fossil alternatives). Pellets 
from processed forest residues (i.e. post-processi ng) has not been included in the graph as it is 
assumed that it has similar emissions to pellets from forest residues in the EU68. Black liqueur 
is also not considered as it is difficult to imag ine black liquor being sold outside the pulp mill. 
It is therefore considered as a waste.  
In these calculations, land use emissions are a ssumed to be zero, the assumption being that no 
land conversion is taking place to produce the biomass, as in the case of waste or sustainably managed forests. It should be noted that th is can normally be expe cted to be the case, 
especially as the EU is experiencing a fforestation rather than deforestation. 
The greenhouse gas emissions performance figur es for forest biomass are supported by the 
UK's Environment Agency report
69, which finds that the worst case scenario for chips from 
forest residues is 82% saving (bearing in mind that a different methodology was used to 
calculate the savings). In contrast, for pellets and chips from short-rotation coppicing (SRC)70, 
greenhouse gas savings range from 38% to 81%  respectively (when co mpared to natural 
gas71). In the RES Directive default values we re set for each biofuel chain, making default 
values conservative enough so as to be set at a level that is typical of normal production 
processes where the contribution to overall emi ssions is small. These default values were 
                                                 
68 Pellets (and charcoal) are normally produced from sa wmill residues (not short rotation coppicing) as a 
high level of dryness and bark removal is required.  
69 Environment Agency (2009) "Minimising greenhouse gas emissions from biomass energy generation" 
70 Short rotation coppicing is considered as agriculture in this analysis, as usually arable land is used. 
71 These figures are based on a different methodology to the one proposed in Annex V, where for instance 
the comparator is not natural gas, but average EU fossil heat or electricity. 
 
EN 35   EN calculated by increasing the assumed emissions  from production by 40%. As the production 
emissions is routinely low (below 1g CO2e q/MJ biomass for forest residues (FR) and 
between 2-6g CO2eq/MJ for wood from short ro tation forestry (SRC)),  the default value 
would still in most cases l ead to above 80% savings.  
It could be argued that some of the possi ble greenhouse gas emissions saving opportunities 
are already tackled elsewhere. In case of municipal solid wa ste, under the Waste Framework 
Directive, waste incinerator operators have to  meet a given energy efficiency threshold. 
Moreover, there are also incentives to redu ce GHG emission in general through the ETS and 
the GHG reduction targets agreed. Nevertheless t hose incentives do not create standards to 
ensure that those with the worst performance are avoided. 
The GHG savings in almost all cases are significant compared to the EU average fossil 
alternatives. This indicates that production of  bio-energy from solid biomass and from biogas 
typically delivers significant greenhouse gas savi ngs (compared to foss il alternatives). In 
these calculations, land use emissi ons are assumed to be zero, as in  the case of forest or waste 
biomass, the assumption is that no land conversi on is taking place to produce the biomass. As 
stated above, this can be expected to be th e case, especially as the EU is experiencing 
afforestation rather than deforestation. 
Given the data above, Options B2 woul d not lead to additional GHG savings.  
Option B3 will lead to between 5-20% addition al GHG savings for some pathways which fall 
below 35% and 50-60% (maize biogas, charcoal and pellets from short rotation coppicing 
from tropical regions). For feed stocks such as charcoal, the impact is not likely to be 
significant because charcoal is mainly used by small-scale users in developing countries for 
cooking and heating and for recreational use (barbeque s) in the EU. It is not likely that putting 
minimum GHG requirements on charcoal would deliv er much more environmental benefits in 
terms of GHG reduction in the EU72. Option B3 would also ensure that minimum GHG 
requirements are set in line with the RES-Di rective and provides consistency for those 
feedstocks that can be used both for transpor t purposes (biofuels) and for electricity and 
heating, such as straw, energy grasses and energy crops. 
Option B4 will lead to some additional GHG sa vings by leading to improvements in the 
chain, such as using wood instead of natural gas for the processing fuel. This could lead to an 
additional saving of around 15g CO2 eq/ MJ energy. In the case of pelletising, switching from 
natural gas to wood as proce ss fuel, would lead to an improvement of around 35% GHG 
savings for electricity production. 
5.2.2. Economic impacts a. Costs to public administrations Options B3/B4 have higher cost because more claims from economic ope rators would have to 
be checked.  
                                                
 
72 Trade in charcoal from Africa to the EU is not signi ficant, however. The largest importers of charcoal in 
the EU (Germany, Poland, Spain, Bulgaria and UK) s ource charcoal mainly from other countries inside 
the EU (the largest exporters of charcoal are Po land, France and Germany). The largest exporters to 
Europe are Malaysia and Indonesia. The largest ex porter from Africa is South Africa which does have 
strong policies on reforestation and forest management. 
 
EN 36   EN The cost for Options B3 and B4 were calculat ed using the EU's standard cost-model (see 
COWI Consortium 2009).  
Table 3: Costs of GHG verification on public administrations (EU-27) 
Type of costs  Low cost 
scenario 
(€/year) High cost 
scenario 
(€/year) 
One-off costs €0.3 
million €1.1 million 
Recurring costs €0.1 million €0.2 million 
A single threshold for GHG savings under Option B3 may decrease the administrative burden 
to a certain extent, as it delivers consistency in  applications which can  generate both heating 
and electricity. In order to take account of differe nces in processing of feedstocks, an option is 
to develop default values for pathways using na tural gas or using wood as process fuel. This 
would enable a single threshold to be used under Option B3, while ensuring that differences 
in emissions due to differe nt processes are reflected. 
b. Costs to economic operators Under the RES Directive, economic operators are required to use the mass balance method
73 
to prove chain of custody, because the 'book and claim' method is open to fraud and will not 
deliver a price premium, and the 'track and trace' method is more costly. In the impact 
assessment accompanying the RES Directive, it wa s calculated that cost of mass balance 
chain of custody were about €0.44/ toe or €1.36/ton74. As seen in the case of Electrabel in 
section 5.1.2, these costs will be lower for solid and gaseous biomass users, because less operators are involved in the chain
75. 
The COWI Consortium (2009) found that the cost of GHG certification is substantially higher 
when economic operators have to show actua l GHG savings of the bio-energy chain. Where 
default values are used, the costs to all operators in the chain are 10-20% lower.  
The COWI Consortium calculated the costs for the whole EU-27 using the EU's Standard 
Cost Model. They showed that for processo rs, manufactures, traders and energy producers, 
the recurring costs are 60-70% higher when G HG certification is imposed compared to CoC 
certification alone. One-off costs were unaff ected. As reporting obligations would fall on 
energy producers, their costs increase by an order of 10-20% compared to processors, 
manufacture, traders etc. energy producers). For individual energy producers above 1 MW 
capacity the recurring costs can vary between  €898-5,643 per year. In total, EU-27 energy 
producers (assumed to be around 48,000 entities ), would face one-off costs of between €9.8-
39.4 million, and recurring costs between €68-270 m illion per year (the lower range is based 
on current average wages and the high range on an  assumption that wages would rise 4-fold).  
                                                 
73 A mass balance system would allow the mixing of sustainable and unsustainable wood, but only the 
percentage of sustainable input would count towards the renewable energy target s. Existing certification 
schemes mainly use a method which permits a whole batch of wood to count as sustainable as long as a 
minimum threshold, say 70% is from sustainable sources. 
74 Based on 1 tonne = 0.3215 toe 
75 For forest residues, plants in general receive thei r individual biomass loads di rectly from a supplier, 
even where independent biomass su ppliers organise the purchase. 
 
EN 37   EN c. Economic availability of biomass 
Options B1 and B2 do not have any impact on the economic availability of biomass. Option 
B3 would set a 50-60% minimum threshold for a ll electricity and heat  plants from 2017-2018. 
In order to derive the total economic availabil ity of biomass in 2020 for Option B3, it needs to 
be considered which agricultural biomass pathwa ys (including biomass used for biofuels and 
bioliquids) will not be able to  meet the 50-60 % threshold76. The COWI Consortium (2009) 
carried out an assessment of the possibl e improvements of the GHG performance of 
agricultural biomass pathways, using the following assumptions: 
– a 90% reduction of nitrous oxide emissions in N fertiliser to be realised on a 
relatively short term, 
– a 25% reduction of CO 2 emissions in N fertiliser production by 2020, 
– a 5% reduction of GHG emissions in feedstock production by 2020, for emissions 
other than those related to N fertiliser 
– a 10% reduction of CO 2 emissions in the biofuel pr ocessing industry by 2020, with a 
linear development towards that level from 2008, 
– a 20% average reduction in methane emissions at palm oil mills by 2020, 
– a 15% efficiency improvement of digester and gas engine up to 2020, also valid for 
new plants by 2018, 
– a 40% reduction of methane emissions in pr ocessing, as these are mainly attributed 
to methane slip in the gas engine whic h can be well avoide d by better engine 
management. This assumption also applies to new plants after 2018.  
– a 5% efficiency improvement of the related diesel engines, also valid for new plants 
by 2018; 
– a 10% efficiency improvement in long-distan ce transport, also valid for new plants 
by 2018; 
Using the GHG methodology, the 2017 and 2020 typical greenhouse gas emissions which 
would result from the projected  autonomous emission reductions  were calculated. These are 
summarised in Table 4 below. Many biofuel a nd CHP chains that do not meet the 50-60% 
thresholds by their 2008 values are projected to do so by their 2017 (existing plants) and 2018 
(new plants) values. However, the biofuel chai n that falls short of the 2017 (existing plants) 
50% threshold is: 
– Biodiesel from soy 
The biofuel chains that fall short of th e 2018 (new plants) threshold of 60% are: 
– Wheat ethanol with lignite as process fuel 
                                                 
76 The minimum savings requirement for established plants is 50% from 2017 and for new pants is 60% 
from 2018. 
 
EN 38   EN – Wheat ethanol with natural gas (conv entional boiler) as a process fuel 
– Biodiesel from rapeseed  
– Biodiesel from soy 
– Biodiesel from palm (process not specified) 
Table 4: Typical GHG reduction values for 2008, 2017 and 2020. 
Biofuel, chain Typical GHG 
reduction 
(%) Typical GHG 
reduction 
(%) 2017 Typical GHG 
reduction 
(%) 2018 new 
Bioethanol (1st generation)       
Wheat       
- lignite as process fuel in CHP  32% 41% 42% 
- natural gas as process fuel in conventional 
boiler 45% 53% 54% 
natural gas as process fuel in CHP plant 54% 61% 62% 
Corn (maize)       
- natural gas as process fuel in CHP 56% 61% 62% 
Biodiesel       
- Rape seed 45% 54% 55% 
- Soy bean 40% 43% 44% 
- Palm oil (process not specified) 36% 38% 40% 
Hydrotreated vegetable oil       
- Rape seed 51% 60% 61% 
- Palm oil (process not specified) 40% 45% 47% 
Pure vegetable oil       
- Rape seed 59% 67% 68% 
Electricity and heat pathways    
- Power only on vegetable oils: soy 51% 56% 58% 
- Power only on vegetable oils: palm (no 
CH4 cap) 44% 53% 55% 
 
EN 39   EN It can be seen from Table 4 that for non-bi ofuels, only the power ge neration options on the 
basis of soy and palm (process not speci fied) fall short of the 60% threshold. 
However, it is important to consider the overa ll costs of reaching the 50-60% threshold also 
for other agricultural biomass used for biofuels and bioliquids. This is because in case these 
pathways cannot achieve the threshold, there may be shifts to use different types of 
feedstocks, which may have an impact on the economic availability of biomass and jeopardise 
reaching the 2020 renewable energy ta rgets in a cost-effective way.  
The COWI Consortium (2009) assessed that it is  possible for most pathways to reach the 
threshold at a certain cost.  
For ethanol production from wheat, the most stra ightforward way for the sector is to shift 
their process fuel towards CHP, on the basis of natural gas or biomass. This improves the 
GHG emission reduction to 62% for new plants by 2018 or higher.  
For the biodiesel sector, the first-order optio n would be the introduction of biomethanol 
instead of fossil methanol (detailed data ar e specified in the COWI Consortium 2009 study). 
This option leads to a typical  GHG reduction of 62%. For soy bi odiesel, additional options to 
improve the GHG profile seem to be insufficien t to meet the 50% and the 60% threshold. For 
existing installations by 2017, the 50% thres hold can be met by the introduction of 
biomethanol instead of fossil methanol; it lead s to a GHG emission reduction of just 50%. For 
new installations 2018, a shift in feedstocks for biodiesel would be expected, in which soy is 
phased out and substituted for rapeseed and sunflower. 
For the options using palm (without methane ca pture) that do not meet  the 50% and/or 60% 
threshold, it can be foreseen that methane ca pture will be implemented, which can be done 
relatively cost-effectively. This leads to a t ypical GHG reduction of well over 60%. For power 
generation from palm and soy, it can be assumed that soy oil is substituted by palm oil and that this palm oil can then be fully obtained fr om mills with methane capture. This increases 
the greenhouse gas emission reduction to 75%.  
The impacts of carrying out these improveme nts were assessed by the COWI Consortium 
(2009). Table 5 summarises these costs. All co sts are annual costs for the year 2020; no 
cumulative costs for 2008-2020 were calculated.  
Table 5: Costs of meeting GHG thresholds until 2020 
Biofuel chain Autonomous 
GHG emission reduction  Improvemen
t option Resulting 
GHG emission reduction  Addition
al costs for the year 2020 (linear baseline) Addition
al costs for the year 2020 (2015 biodiesel peak) 
Ethanol from wheat (NG boiler) 54% (2018) Shift to 
natual gas CHP 62% 
(2018) 0 0 
 
EN 40   EN Biodiesel from 
rapeseed 55% (2018) Biomethanol 
in processing 62% 
(2018) 13 M€ 0 
Biodiesel from 
soy 43% (2017) Biomethanol 
in processing 50% 
(2017) 18 M€ 23 M€ 
Biodiesel from 
soy 44% (2018) Shift to rape, 
sunflower >62% 
(2018) 15 M€ 0 
Biodiesel/HVO 
from palm (p.n.s.) 45/47% (2017) 
43/47% (2018) Methane 
capture  > 
62/68%
1 
(2018) 15 M€ 15 M€ 
Total additional costs 61 M€ 38 M€ 
1:62% and 68% are the current t ypical values for respectively biodiesel and HVO from palm 
with methane capture at oil m ill. 2017 and 2018 values have not been calculated but will be 
above these values. 
A full shift to methane capture in palm oil pr oduction comes at an esti mated cost of 0,2 €/GJ 
palm oil. The estimated 4 PJ of palm oil use as a bioliquid in power  generation would then 
lead to additional costs in the order of € 1 million.  
In sum, it is not expected that Option B3 will have any impact on the economic availability of 
biomass. There will however be some complian ce costs mainly affecting the biofuels and 
bioliquids industry to improve their GHG performance. But this is a consequence of the RES 
Directive.  
Option B4 would also not have an impact on economic availabil ity of biomass, as it is 
assumed that high GHG requirements for forest  biomass can be achieved by the sector. 
However, the additional compliance costs asso ciated with Option B4 would not lead to 
significant additional GHG savings as  identified in section 5.2.1. 
5.2.3. Social impacts It is not expected that the GHG savings obliga tions could be reasonably put on households, as 
it would be difficult to monitor their GHG savi ngs. If households are exempted from these 
requirements, there is no impact on households . Employment effects are also considered 
negligible from putting in place gr eenhouse gas performance criteria. 
5.2.4. Impacts on third country actors The total administrative costs associated with  complying with GHG criteria are difficult to 
quantify as the number of actors who may be a ffected is highly uncertain. It is however 
possible to assume that the administrative cost s per economic operator wi ll be similar to those 
calculated for EU actors. The COWI Consortium calculated costs for forest owners and 
farmers producing short rotati on coppicing, as well as for w ood processors manufacturing 
secondary woodfuels or raw materials for thes e (saw mills, pulp and paper mills, pellet and 
 
EN 41   EN briquette factories) and biomass traders. The costs for these target groups are detailed in the 
COWI Consortium's report, a nd are summarised below:  
Table 6: Administrative costs of GHG veri fication per biomass producer/ processors 
and traders 
Type of costs Biomass 
producers  Processors and 
traders 
One-off costs €205-820 €205-820 
Recurring costs €769-3076/ 
year €898-3593/ 
year 
Some third country producers, su ch as pellet factories, alre ady provide evidence of meeting 
CO2 performance requirements, e.g. under comp any schemes such as the Laborelec scheme. 
5.2.5 Summary of impacts 
Table 7: Summary of impacts of policy options to ensure GHG savings 
 Costs to 
public 
administratio
n (EU-27) Econo
mic 
availabi
lity of 
biomass Costs to 
economic 
operators  Environmental impacts 
Biodiversity and Land 
use House
holds Employ
ment 
A. Production    
Option B1: no 
new EU action 0 
No effect 0 
No 
effect 0 
No effect 0 
Does not contribute to 
additional GHG savings  0 
No 
effect 0 
No 
effect 
Option B2: labelling of 
GHG 
performance - 
Costs to set up 
scheme and 
provide 
labelling 0 
No 
effect - 
Some additional 
costs for labelling 
scheme 0 
No significant benefit, as 
differences in GHG 
performance are difficult 
to distinguish for most 
consumers of heat/ 
electricity 0 
No 
effect 0 
No 
effect 
Option B3: 35% (increasing to 
50-60% in 
2017/2018) GHG savings 
for 
agricultural + forestry 
pathways - 
Costs due to 
verification of 
GHG criteria 0  
No 
significa
nt 
change  - 
Some additional 
costs if biomass 
pathway does not 
typically reach 
GHG performance 
requirement + 
Some additional GHG 
savings (5% for biogas 
based on crops and 5-
20% for SRC charcoal 
and 5-10% for charcoal 
from forest residues) 0  
No 
effect  0  
No 
effect  
Option B4: 
GHG thresholds in accordance 
with GHG 
saving 
potential 
(except for waste - 
Costs due to 
verification of 
GHG criteria  0 
No 
significa
nt 
change  - 
Some additional 
costs if biomass 
pathway does not 
typically reach 
GHG performance 
requirement +  
some additional GHG 
savings depending on the 
thresholds (e.g. pellets 
using wood as process 
fuel deliver 35% savings 
compared to pellet using 
natural gas as process 
fuel)   0 
No 
effect   0 
No 
effect  
 
EN 42   EN biomass) 
Table 7 shows that that Options B3 and B4  would bring some additional environmental 
benefits in terms of GHG perf ormance. Option B1 would not provide safeguards against some 
energy intensive practices and Option B2 would not bring any additional environmental benefits as there would be no mi nimum standards set. In partic ular, there are some pathways 
where high GHG performance may not be assured. This is partly because consumers would 
not be able to judge between good and bad practices without benchmarks.  
The potential additional GHG savings over the lif e cycle are not immensely significant for 
Option B3 and B4. In particul ar, the additional burden of having different GHG requirements 
for different pathways (Option B4) may not out weigh the benefits of the additional GHG 
savings in all cases. This is because most of  the pathways routinely achieve high (usually 
more than 80% GHG savings) throughout the lifecy cle. Administrative costs are reduced if 
the GHG requirements are consistent over all biom ass feedstocks (whether used as transport 
biofuels or for electricity and heat), as propos ed in option B3. To take account the largest 
differences in emissions, i.e. due to the fuel  used for processing, an option is to develop 
different default values for pathways dependi ng on the process fuel. This would limit the 
administrative burden while ensuring that differe nces in emissions due to different processes 
are reflected. 
5.3 Policy Options to foster higher en d-conversion efficiency of biomass 
Option C1: No new EU action 
Option C2: Bonus for better end-conversion efficien cy or penalty for lower end-conversion efficiency 
Option C3: Minimum efficiency standards 
Policy options for different technology combinations 
The policy options will produce very differe nt incentives for the different technology 
combinations and stakeholder groups.  
Users of dedicated large scale power and CHP plants  are usually well-informed and motivated 
by subsidies or other support mechanisms. Mo st efficiency improvements can be made 
through technology add-on’s and heat use of these large installations. A bonus/ penalty 
system for higher efficiency or minimum perfor mance standard for new installations could be 
appropriate policy measures as most installations  already perform at their optimal efficiency 
and for further improvements additional investments are necessary through using ‘add on’ technology or to make more use of the heat pr oduced. Therefore a specific attention on using 
heat in the bonus system could be considere d. In Belgium for instan ce, in the Walloon and 
Brussels regions, subsidies are granted base d upon the avoided fossil CO2 emissions with 
respect to a reference fossil plant, based on an LCA analysis, including the efficiency of the 
plant
77. This means that biomass is not considered as fully CO2 neutral for the purposes of the 
Green certificate scheme, and in many cases powe r-only co-firing plants with coal would not 
meat requirements to benefit from the subsidy scheme.  
                                                 
77 Van Stappen, Marchal, Ryckmans, Crehay, Schenkel  "Green Certificate Mechanisms in Belgium: A 
useful instrument to mitigate GHG emissions", Laborelec/ Electrabel 
 
EN 43   EN Minimum performance standards for new installa tions might also be feasible, because these 
can be integrated in the design of a new inst allation. For dedicated la rge scale in stallations 
minimum performance standards could be a feas ible way to stimulate either use of heat 
produced or use of add-on’s to increase el ectricity production. Under the Eco-design 
Directive, the Commission has already undert aken a study on the energy efficiency of 
industrial ovens and furnaces that  will cover all poten tial fuel sources, including biomass. 
Results of this study will be available at the end of 2011.  
Labelling is not a feasible policy option for la rge scale power and CHP installations, because 
it is not a consumer good and acquiring such large installations is guided more by financial or 
technical reasons. 
In co-firing plants , subsidy schemes are usually the drivers of the use of biomass, but it has to 
be born in mind that the original  purpose of co-firing installations  is not to provide bio-energy 
but to provide fossil energy. Se tting minimum requirements for installations using biomass 
and not for other fossil fuels, may lead to decr eased use of biomass in  co-firing plants. Energy 
efficiency policies looking at all fuels theref ore would be more appropriate in increasing 
energy conversion efficiency in this case.  
The case of waste incineration  is comparable to co-firing as main objective of energy 
recovery of waste is not energy generati on but waste management. Setting minimum 
efficiency requirements for biodegradable wa stes might therefore result in reducing the 
potential of green electricity produced from a fe edstock with no alternative use (unless it is 
biologically treated). A bonus/ penalty system  for higher efficiency  may be an option, 
stimulating small increases in the installati on due to technical performances and process 
management. The Waste Framework Directiv e also has some incentives for improving 
efficiency. It sets minimum efficiency re quirements to serve as a threshold for the 
classification of waste incinera tion as recovery operation instead  of as disposal operation. 
In the case of co-digestion , methane emissions are reduced compared to conventional manure 
storage and spreading, or from landfilling bio-wa stes, energy is produced and the digestate is 
a more valuable fertilizer than the manure its elf. Large improvements could be made in 
efficiency due to heat use, up-scaling etc, but efficiency measures should not limit/discourage the practice of digesting given the environm ental advantages (and waste management 
objectives). Therefore for wast e digestion the most suitable  policy option would be a bonus/ 
penalty system.  
District heating
 systems are more efficient than i ndividual heating systems therefore 
stimulation of those systems would increase e fficiency. However the c onstruction of district 
heating systems is quite costly. In several countries district heating systems already exist, 
which makes connection to the network with a new provider of energy relatively easy. This 
generates different opportunities an d different policy options releva nt for different regions in 
Europe. It must also be possible to fit the system with the local demand present. A bonus / 
penalty system could help optimise the system  by stimulation CHP’s which can also provide 
electricity. 
Table 8 below depicts the pos sible efficiency improvement s of the different biomass 
technology combinations and summa rises the possible policy options  to be used to stimulate 
increased end-conversion effi ciency of the different technology combinations.  
 
EN 44   EN Table 8 (from Ecorys report 2009, tabl e 21): Summary of biomass technology 
combinations and their impr oved efficiency potentials 
 Main 
countries 
of 
applicatio
n Typical 
efficienc
y % Order of 
magnitude 
of estimated 
current 
capacity Order of 
magnitude 
estimate of 
maximum 
potential Efficiency 
improvement
s  Possible policy 
options 
Large scale 
power and 
CHP  FI, DK, SE, 
EE, LV, 
LT, AT 10-30 
electrical 4.7GWe  
(+ unknown 
amount of heat) 5.8 MWe 
at ηe=20%->25% 
15 GWth at full heat 
utilization Large scale; 
heat utilization; 
-Improved heat 
Recovery by 
ORC of flue 
gas condenser - Bonus/ penalty 
system for 
efficiency improvement 
-Minimum 
efficiency 
standard 
Co-firing DE, FI, 
UK, NL  35-43 
electrical 1.2 GWe 8.3 GWe based on 
total technical 
potential Heat utilization 
-(Improve 
impact: increase market 
penetration) -No specific 
efficiency related 
policies 
-Efficiency is 
already high, with 
possibilities for stimulation of co-
firing in general 
Waste incineration DE, NL, 
DK, SE, 
LU 15-30 
electrical 2.2 GWe 3.8 GWe when all 
MSW is incinerated 
(no landfill) - Higher steam 
pressures; 
-Corrosion 
resistant 
materials; 
-Heat 
utilization  - Bonus/ penalty 
system for 
efficiency improvement  
Power Plant 
ORC AT, DE 6-20 
electrical Unknown Unknown -Autonomous 
improvement 
of this new technology -Bonus/ penalty 
system for 
efficiency improvement 
-Minimum 
efficiency standard 
District heating SE, FI, DK, 
EE, LV, 
AT 80-90 
thermal 126 GWth Improving 
efficiency from 
ηth80%->90% 
reduces primary energy 
consumption with 
26PJ->14.4 GWth installed capacity -Improved heat 
recovery by 
e.g. flue gas 
condensation; 
-Boiler 
efficiency 
improvements -Investment 
Subsidy 
-Minimum 
efficiency standard 
 
Manure 
(co)digestion DE, DK, 
AT, NL, 
IT, PT, HU Not 
relevant 
(motor: 
38-42 1667 MWe 2037MWth (at 
electrical efficiency 
of 36%); 1852 MWe 
and 1852 MWth 
when electrical -Heat 
utilization; 
-Avoid small 
scale gas -Bonus/ penalty 
system for 
efficiency 
improvement 
 
EN 45   EN electrical) efficiency is 40% 
(scale advantages) engines 
Diesel engines 
on vegetable 
oils IT, DE 40-48 
electrical Unknown Unknown -Heat 
utilization; 
-Avoid small 
scale diesel 
engines -Bonus/ penalty 
system for efficiency 
improvement 
-Minimum 
efficiency 
standard 
Option C2 (Bonus/ penalty system) is best ap plicable where significant improvements in 
efficiency can be made, due to the costs for gove rnment. In this sense, stimulation of heat & 
power production over stand-alon e electricity production plants brings additional energy 
savings, and reducing one-sided stimulation of electricity in  current support schemes will 
create an incentive for this. A st ep-wise bonus system is a tool effectively used in some 
Member States to stimulate heat use. A bonus system is especially interesting for already 
existing installations. For new installations the use of heat can be taken into account in 
construction increasing the improvements obtained in the future. A bonus system is also most 
effective when installations serve other goals: su ch as waste treatment, as minimum efficiency 
requirements may hamper the supply of the main service of such plants.  
Option C3 (minimum efficiency standards) is e ffective in excluding the application of certain 
inefficient biomass pathways. In principle this option can be applied to all biomass conversion 
installations, in particular to new installations, because these can be integrated in the design of 
a new installation. For dedicated large scale installations minimum performance standards 
could be a feasible way to stimulate either use of heat produced or use of add-on’s to increase 
electricity production. However, there is a risk that economic operators will make a different 
economic calculation on the use of biomass and mi nimum standards might lead to the use of 
more fossil energy if the same standards do not also apply to fossil fuel applications. 
Moreover, the use of biomass waste streams wh ich have no other use (e.g. manure), may be 
disincentivised.  
5.3.1. Environmental Impacts 
The impacts of higher efficiency gains on GHG performance are discussed under policy 
options to reduce GHG emissions. Overall GHG savi ngs throughout the life cycle of existing 
biomass plants are only marginal compared to increasing the replacement of fossil fuels with 
biomass. In general the impact of end-conversio n efficiency improvements of existing plants 
depends on what the biomass technologies ar e being compared to. When compared with 
similar size fossil fuel plants, there are hard ly any differences in GHG improvements due to 
increased efficiency.  
However, the policy options considered could have positive environmental effects if the 
policies result in more efficient use of biomass. The availability of biomass becomes a constraint on the scope for replacing fossil fu els. In that case, pos itive impacts would be 
dependent on the effectiveness of the differe nt policy options to replace fossil fuel 
alternatives.  
Table 7 in section 5.3.1 shows the range of e fficiency improvements achievable by different 
technology combinations (typical efficiency). The biggest improvements could come from 
utilising the heat in electricity only pl ants (i.e. switching to biomass CHP).  
 
EN 46   EN Therefore policies which can encourage these improvements will have the highest 
environmental benefits.  
Under Option C3, if minimum efficiency standard s are set only for biomass and not for fossil 
fuels, the environmental impacts can be negative.  Coherent energy efficiency policy is needed 
therefore on all energy production not  only for bio-energy production.  
Under Option C2 (bonus/ penalty),  the negative impacts of switching away from biomass to 
fossil would be avoided, as a bonus usually means an additional incentive on top of other incentives to use renewable energy (e.g. more green  certificates, price pr emium on top of feed 
in tariffs, investment subsidy etc). It is however important that Member States would set 
efficiency requirements to get a bonus at a level whic h is achievable for th e specific biomass 
technology combinations. 
5.3.2. Economic impacts a. Costs to public administration 
The administrative costs associated with each policy option are relatively low. They can be 
higher when there are disperse  and diverse target groups. Ec orys estimated administrative 
costs using the EU standard cost model (See Ecorys 2009).  
 Total Administrative Costs 
No. Type of obligation  Low cost 
scenario High cost 
scenario 
C2a Bonus/ penalty system for large-
scale power and CHP €592,463 €2,369,852 
C2b Bonus/ penalty system for waste 
incineration €404,240 €1,616,960 
C2c Bonus/ penalty system for co-
digestion €443,264 €1,773,056 
C3b Minimum efficiency standard for 
large scale power and CHP €695,217 €2,780,868 
C3c Minimum efficiency standard for 
district heating €934,573 €3,738,293 
For Option C2, there may be additional cost s to governments. This could depend on the 
support scheme used in Member States. In Aust ria, the support framework for highly efficient 
renewable electricity production is provided th rough the "Eco-Power Act" in 2003 which lays 
down criteria for energy efficiency (investments fo r installation of the h eat extraction part are 
subsidised depending on the ensured heat extract ion with 15%–30% of the investment cost), 
and provides a purchasing obligation and tariff s upport, which are funded via an extra charge 
on the electricity price.78 (Electricity prices for househol ds have increased from €13.19/ 
100kWh in 2004 to €14.09/kWh in 200779).  
b. Costs to economic operators 
                                                 
78 http://www.cospp.com/display_article/314976/122/ ARCHI/none/none/1/CHP-support-mechanisms-in-
different-countries---from-feed-in- tariffs-to-investment-incentives/ 
79 Eurostat, taxes included 
 
EN 47   EN The cost of increasing efficienci es of the different types of biomass plants was studied by 
Ecorys (2009). In general, improvements in  end-conversion effici ency can be achieved 
through: 
– using the produced heat 
– application of add-on's to increase  electricity or heat production 
– technology improvements of the combustion technology 
– increase the plant size (capacity)80  
The costs include the costs companies have to ma ke to incur to comply with new legislation. 
In this case, costs necessary to improve the conversion efficiency of the biomass technology 
combination. The large variety of installati ons generating bioenergy obviously makes it 
difficult to give a reliable indication of these co sts. The table in Annex VI gives examples of 
the costs to improve the end-conversion efficiency for different technologies. 
Policy option C2 (bonus/ penalty), does not fo rce companies to implement efficiency 
improvements, because a bonus does not exclude  less efficient biomass plants. It is a 
voluntary measure, where a company is free to make use of the bonus. Only when companies 
are forced to comply with new efficiency standards, do actual compliance costs occur.  
Where companies would need to comply with  minimum efficiency standards, an overall 
quantification of compliance and administrative costs are presented in the table in Annex VI. 
It should be noted that the replacement rate, as  presented in the table can be subjected to 
variation due to the set up of possible support schemes or le gislation. A low and a high 
scenario are presented to indicate the range in gains that can be obtained. As efficiency 
improvements of around 8% are already assumed in the baseline scenario for new electricity 
plants, it can be concluded that  the largest gains in end-use efficiency improvement can be 
obtained through use of heat in new installa tions. Nevertheless, an option for minimum 
efficiency requirements, which would require th e use of heat, would le ad to considerable 
compliance costs, between €50-200 million per installation. 
c. Economic availability of biomass The impacts on availability of biomass are de duced from the total savings of replacing 
efficient technologies with inefficient ones. Th e baseline scenario al ready takes account of 
increases in efficiency, through technology learning. If any impact ar ises, it is lik ely to be a 
positive one, as a product of using less biomass to replace more fossil.  
5.3.3. Social impacts a. Households Minimum efficiency requirements or bonus/ penalty  for large scale systems is not expected to 
have an impact on households, unless the extra costs to bio-energy plants are passed onto 
consumers in terms of higher prices for energy. This may lead to a substitution effect where 
                                                
 
80 Although scale and size of an installation is moreover determined by location, supply of feedstock and 
an optimum cost effectiveness and scale. 
 
EN 48   EN money for consumption is shifted from other go ods to the consumption of energy. However, 
if the additional investment, maintenanc e and operation for biomass induce more 
employment, the households will have more mo ney available for consumption (total income 
of household increases). This might compensa te the negative price effect and increase 
consumption. 
b. Employment Employment impacts can arise where the mini mum efficiency requirements under Option C3 
result in a need for upgrading systems. An in crease in investments in creases the demand in 
biomass related services and biomass-technol ogy producing sectors. Hence, an increased 
demand leads to an augmentation of the production in these sectors. There will be sectors that 
are indirectly affected by the policy options , such as suppliers of biomass-technology 
producers or service providers lik e the forest and agricultural sectors, transportation sector 
etc. Besides the suppliers of the biomass tec hnology producing sector, we  also have to take 
into account the effect of biomass promoti on on the fossil energy generation sector. 
Conventional investments in this sector will decrease since the generation of fossil energy 
will be replaced by biomass. Hence, revenues an d employment will decrease at conventional 
(fossil) energy technology producer s and service providers as we ll as at the suppliers of 
technology producers.  
The employment effects are not expected to be  significant, as the t echnological improvements 
needed to reach the 2020 targets have already been considered studying the baseline. Only 
where there are minimum efficiency standa rds introduced could some positive employment 
effects arise, given that the efficiency stan dards are set in a way that ensures continuing 
investments into the biomass sector.  
5.3.4 Summary of impacts 
Table 9: Summary of impacts of the po licy options to fost er energy efficiency 
 Cost to public 
administrations 
(EU-27) Costs to 
economic 
operators Economic 
availability 
(EU 27) Environment
al impacts 
 Employme
nt Households 
Option C1: 
Business as usual 0 
No effect 0 
No effect 0 
No effect 0 
No effect  0 
No effect 0 
No effect 
Option C2: Bonus for better end-conversion 
efficiency 
or penalty for lower 
end-
conversion efficiency - 
Low additional 
administrative 
costs, as can be 
included in 
existing support 
scheme, but high 
costs for 
governments. + 
additional 
operation and 
investment 
costs are 
compensated 
by bonus and 
lower 
performing 
installation 
are not 
excluded 
from support. 
 + 
More efficient 
burning of 
biomass leads to 
less quantity of 
biomass used 
per energy 
produced +  
leads to more 
effective use 
of resources 0 
Some 
additional 
jobs from 
investments 
effects, but 
the impacts 
are 
negligible 0 
No effect 
Option C3: -- 
High costs of -- 
High + 
More efficient Depends on 
response to + 
Additional - 
Increased 
 
EN 49   EN  Cost to public 
administrations 
(EU-27) Costs to 
economic 
operators Economic 
availability 
(EU 27) Environment
al impacts 
 Employme
nt Households 
minimum 
efficiency standards setting up 
schemes to 
enforce standards. increase in 
compliance 
costs where 
existing 
installations 
have to be 
upgraded, 
moderate 
when applied 
to new 
installations 
only burning of 
biomass leads to 
less quantity of 
biomass used 
per energy 
produced standards: 
 
- if biomass 
stoves are 
replaced by 
fossil 
 
+ when a 
standard leads 
to more 
effective use 
of resources jobs from 
investment 
effects energy costs 
on 
consumers 
Table 9 shows that option C1 has no effect on further improving end conversion efficiency. 
The environmental impacts of Options C3 depe nd on wider energy efficiency policy for fossil 
alternatives. Negative impacts can occur where th e policy would lead to a shift from biomass 
to fossil use. In terms of costs, Option C3 (minimum requirements) is not effective if 
minimum requirements on fossil alternatives do not  occur at the same time and this option has 
high administrative and compliance costs. Opti on C2 (bonus/ penalty) could be costly to 
governments, but it is the effec tive option in terms of deliveri ng environmental benefits, while 
ensuring low compliance costs.  
 
EN 50   EN Section 6: Comparing the options 
The options can be compared in accord ance with the following requirements: 
- consistency with other policies: biomass is a resource that can be used in liquid, solid or 
gaseous form to produce transport biofuels, heat  or electricity. There should not be different 
sustainability requirements for biomass dependi ng on the end-use. There should also not be 
requirements for biomass and not fossil alternatives if this will lead to more fossil being used instead.  
- effectiveness: the policy options ability to  ensure minimum requirements are in pace to 
avoid deforestation, loss of biodiversity and given that th ere is a maximum potential of 
biomass feedstocks, to avoid overuse of the resource.  
- costs-efficiency: costs to public administra tion and economic operato rs should not outweigh 
the sustainability benefits, i.e. there should be proportionality in putting burden on 
administrations and industry. Burden is proportiona te if real improvements in sustainability 
can be made.  
The impacts of the different options can be compared as follows: 
Positive effect 
Moderate effect 
Negative effect 
Not relevant X 
 
 Effectiveness in 
achieving objectives 
 Efficiency  
(cost-effectiveness)  Consistency 
(with policy structures and 
socio-economic 
developments) 
Option A1: no new EU action  Ineffective in avoiding 
negative land use changes  Not relevant 
X Inconsistent with biofuels 
policy  
Option A3: minimum 
biodiversity and land use 
criteria  Effective in ensuring 
further safeguards against 
negative land use changes  Administrative costs 
minimised as verification 
scheme for origin of biomass 
is required under RES-
Directive  Consistent with biofuels 
policy 
Option A4a: Option A3 + 
mandatory reporting and 
monitoring SFM  Effective in ensuring 
further safeguards against 
negative land use changes 
and effective in informing 
decision-makers about 
future trends  Administrative costs can be 
minimized where reporting is 
based on existing voluntary 
reporting tools (e.g. MCPFE)  Consistent with biofuels and 
with global SFM policies  
Option A5: Option A3 + 
SFM obligation  Effective in avoiding 
negative land use impacts High administrative costs for 
monitoring implementation of Consistent with EU policy 
objectives to tackle Legend: 
 
EN 51   EN  Effectiveness in 
achieving objectives 
 Efficiency  
(cost-effectiveness)  Consistency 
(with policy structures and 
socio-economic 
developments) 
as well as ensuring SFM  SFM criteria and for 
certification of SFM  deforestation and forest 
degradation  
Option B1: no new EU action  May lead to some biomass 
pathways not achieving 
high GHG performance  Not relevant 
X Inconsistency of accounting 
GHG emissions for 
agricultural biomass under 
the RED  
Option B2: labelling of GHG 
performance  Effective only for 
consumer products not 
large scale plants  Some costs to administrations 
and to economic operators 
 Not relevant 
X 
Option B3: minimum GHG 
savings threshold for 
agricultural and forestry 
pathways of 35% (increasing 
to 50-60% in 2017/2018)  Effective in avoiding 
pathways with low GHG 
performance  Some costs for verification of 
GHG performance  Consistent with biofuels 
policy 
Option B4: Minimum GHG 
performance in accordance 
with GHG performance 
potential (except for waste 
biomass)  Effective in avoiding 
worst practices and 
lowering GHG emissions  Some costs for verification of 
GHG performance  Consistent with GHG 
emissions reduction policy, 
but not with biofuels policy 
e.g. second generation 
biofuels  
Option C1 – no new EU 
action 
 Some improvement due to 
existing policies 
 Not relevant 
X Not relevant 
X 
Option C2 - Bonus or penalty 
 Effective as bio-energy 
producers receive a direct 
incentive, but the effect 
depends on bonus/ penalty 
structure  Cost for governments can be 
significant  Easily included in 
existing policy framework 
and in line with general 
approach to reward good 
behaviour 
 
Option C3 - Minimum 
efficiency 
performance 
standards 
 Effective in excluding 
poor performing 
installations, but difficult 
to set 
unambiguous thresholds  High compliance costs to 
economic operators if applied 
to existing installations 
 Requires development of 
new policy instrument and 
may conflict with aims of 
other policies (promotion of 
renewables vs fossil, waste 
treatment, rural 
development, security of 
supply)  
On the production side, in the light of the an alysis summarised above, the policy option for 
putting in place minimum requirements for a voidance of biomass production from highly 
biodiverse lands and avoidance of negative land use change (i.e. same criteria as in RES 
Directive) is the best one from a cost-efficien cy point of view. Setting minimum thresholds or 
obligations for sustainable forest management could lead to high costs for industry. On the 
other hand, reporting the origin of biomass us ed for energy purposes is recommended, to 
 
EN 52   EN improve statistics on biomass use and to monito r the effects of biomas s use on the areas of 
origin. Member States could keep  a record of the origin of biomass used for energy purposes, 
and the Commission would periodically monitor those areas. If, thro ugh monitoring, it is 
found that there are areas where forests were not regenerated, proposals could be made for 
corrective action. The country of origin's acco unting for LULUCF emissions could serve as 
one of the factors in monitori ng. For biomass used in household s, Member States can monitor 
the use of biomass through surveys.  
As regards greenhouse gas performance, it is re commended that for consistency operators use 
an EU-wide harmonised GHG methodology to calcu late emissions. Also for reasons of 
consistency, biofuels, bioliquids and solid and gaseous biomass should meet the same GHG 
requirements. This will avoid distortions in the market. Therefore, the minimum GHG savings 
requirement should be set at 35%, increasing to 50% from 2017 for existing plants and 60% 
for new plants from 2018. It is recognised how ever that wastes and processing residues which 
routinely achieve high gree nhouse gas savings should not be  required to reach these 
requirements, as including them would not affo rd important environmental benefits, while 
adding costs to operators. 
On improving efficiency, it is clear that most of  the policy options would only be effective if 
fossil alternatives were also covered by th em. It is therefore recommended not to set 
efficiency standards only for biomass pathways, because that may encourage more fossil energy being used instead. Moreover, it is difficu lt to set the right incentives without thinking 
about the technology that it will be applied to . The assessment shows th at efficiencies of 
different technologies cannot be compared (because often they se rve different purposes, e.g. 
waste management) and that all technologies have a role to pl ay. For this reason, Member 
States should use a bonus/ penalty in their sup port schemes for higher efficiency levels for 
large (non-residential) electricity  and heat installations of at least 1MW capacity. It would be 
for Member States to determine the detailed design of their scheme.  
6.1. Possible EU initiatives to implement the policy options Setting binding EU sustainability requirements for solid and gaseous biomass would enable 
consistency of requirements for the producers and users of biomass for energy purposes. 
However, biomass can be used for other purpos es than energy, and policy developments in 
forestry, agriculture, waste, climate action etc. also need to be taken into account when considering EU-wide action. Many of the problem s that need to be tackled, such as 
deforestation, have a much broade r set of causes than the energy sector. Setting requirements 
only for the energy uses of biomass is not likely to go far enough in solving the wider 
problems. 
The choice of whether or not to set binding crite ria has to also consider the administrative 
burden to actors in the EU whic h, today, can already be seen to be acting sustainably, even in 
the absence of such criteria. This includes small and medium sized enterprises where the administrative costs will be more significant. Th is impact assessment suggests that bio-energy 
producers below 1MW capacity should be consid ered small-scale and should not be covered 
by sustainability criteria. Some Member St ates have hundreds of small producers which 
operate plants of between 1-2MW. Setting such a threshold therefore could have different cost 
implications on different Member States a nd a uniform approach across the EU may be 
difficult to achieve.  
 
EN 53   EN Analysis of the current situation suggests that the limited imports of biomass and the largely 
sufficient environmental performance inside the EU can give certain guarantees of the 
sustainability of biomass production and use. As a result, and in order to respect the "better 
regulation principle", it is proposed to use as  far as possible existin g instruments in the 
environmental, forestry, waste and agricultural policies both at EU and national level. This 
would suggest that binding crite ria for the use of solid and gaseous biomass specifically for 
energy purposes should not be pr oposed at this stage, and th e ensuing debate should remain 
focused on the issue of biomass sustainability in terms of the wider policy framework and in 
relation to the broad range of uses of biomass.  
This would not prevent those Member States that rely heavily on large-scale imports of 
biomass from countries that may not have in place adequate environmental laws or governance structures from setting up their own safeguards. It would seem appropriate for 
such safeguards to be based on the recommen ded policy options identified in this impact 
assessment.  
On the other hand, a lack of binding criteria may lead to unwanted effects, such as the 
development of widely different  national schemes which may cause disruption to the internal 
market. Therefore it is important  that national schemes are deve loped in a way to prevent any 
disruption to the internal market. This factor ma y play a part in future assessment of the need 
for Union legislation on the issues cons idered in this impact assessment. 
Future reflections by the Commi ssion on the need for Union action will also be able to take 
into account Member States' national renewable en ergy action plans, requ ired by Article 4 of 
the RES Directive. These action plans are due to be submitted by the end of June 2010, and will give further indications about Member St ates' plans to support the use of biomass for 
energy purposes. The development of biomass production and trade can then be monitored 
through national reporting, to determine wh ether Community action may be necessary. 
In summary, it is proposed to present recommenda tions for sustainability criteria for solid and 
gaseous biomass used for electricity and hea ting purposes, allowing Memb er States which are 
concerned about unsustainable uses, to put in place approaches that are consistent with the 
RES Directive. The Commission would encourage su ch Member States to work together to 
develop common approaches.  
It has to be pointed out however , that such an approach woul d not allow Member States to 
refuse to count biomass which does not fulfil th e obligations of the national scheme towards 
the renewable energy targets. Member States could however decide not to give financial 
support for biomass not meeting the national criteria.  
Section 7: Monitoring and evaluation 
The core indicator for meeting the objectives is  the increasing use of biomass without leading 
to deforestation, forest degradation, the impoveri shment of agricultural soils, or higher GHG 
emissions. Reporting and monitoring systems are avai lable in particular at EU level, but will 
need to be strengthened for more accurate results. Monitoring requirements under the 
Renewable Energy Directive include the monito ring of commodity price changes associated 
with the use of biomass and any effects on food  security as well as the impact of increased 
demand for biomass on biomass using sectors. 
 
EN 54   EN Eurostat collects information from Member States on forest biomass and bioenergy. New 
requirements for biomass used for energy could be built into those monitoring systems. Data 
collection, map references and information a bout forest management will need to be 
strengthened, including at national level, in the current context. 
 
EN 55   EN ANNEX I – Biomass primary potentials and fu el price for various fractions of biomass 
in the EU (EMPLOY-RES)17 
Potentials (in terms of primary energy) Fuel cost (weighted 
average) 
2005 2020 2005 2020 2005 2020  
Solid biomass 
  GWh  Mtoe  Mtoe  €/MWh-p  €/MWh-p  
AP1 - rape & sunflower 76,617 81,235 6.6 7.0 36.8 54.3 
AP2 - maize, wheat (corn) 144,087 179,996 12.4 15.5 27.3 40.3 
AP3 - maize, wheat (whole plant) 0 207,593 0.0 17.8 0.0 41.2 
AP4 - SRC willow.. 19,860 74,076 1.7 6.4 21.0 35.5 
AP5 - miscanthus 18,246 62,943 1.6 5.4 19.4 37.1 
AP6 - switch grass 31,365 130,318 2.7 11.2 16.3 33.2 
AP7 - sweet sorghum 14,633 43,490 1.3 3.7 40.9 60.7 
AR1 - straw 193,610 315,416 16.6 27.1 12.4 17.9 
AR2 - other agricultural residues 20,452 33,302 1.8 2.9 12.7 18.3 
FP1 - forestry products (current 
use (wood chips, log wood)) 569,356 569,356 49.0 49.0 18.6 24.4 
FP2 - forestry products 
(complementary fellings 
(moderate)) 40,735 96,556 3.5 8.3 21.0 27.6 
FP3 - forestry products 
(complementary fellings 
(expensive)) 61,102 144,834 5.3 12.5 28.4 37.3 
FR1 - black liquor 119,396 138,566 10.3 11.9 6.1 8.0 
FR2 - forestry residues (current 
use) 98,024 98,024 8.4 8.4 7.2 9.4 
FR3 - forestry residues (additional) 22,169 25,857 1.9 2.2 12.9 16.9 
FR4 - demolition wood, industrial 
residues 83,516 97,195 7.2 8.4 5.6 7.1 
FR5 - additional wood processing 
residues (sawmill, bark) 48,679 56,508 4.2 4.9 6.7 8.6 
FR6 - forestry imports from 
abroad 29,740 101,429 2.6 8.7 16.6 25.5 
BW1 - biodegradable fraction of 
municipal waste 149,056 207,815 12.8 17.9 -3.7 -4.7 
Agricultural products 304,809 779,650 26.2 67.0 28.3 41.3 
Agricultural residues 214,061 348,718 18.4 30.0 12.4 17.9 
Forestry products 671,192 810,746 57.7 69.7 19.6 27.1 
Forestry residues 371,784 416,150 32.0 35.8 6.7 8.8 
Biodegradable waste 149,056 207,815 12.8 17.9 -3.7 -4.7 
Forestry imports 29,740 101,429 2.6 8.7 16.6 25.5 
Solid biomass - TOTAL 1,740,644 2,664,508 149.7 229.1 15.5 24.6 
 
 
EN 56   EN ANNEX II – Overview of typical energy conv ersion efficiency of biomass plants 
(EMPLOY-RES)17  
RES-E  
 Plant specification Efficiency 
(electricity) [1] Efficiency 
(heat) [1] Typical 
plant size [MWel] 
Agricultural biogas 
plant  
 28 – 34%  0.1 - 0.5 
Agricultural biogas 
plant - 
CHP  27 – 33% 55 – 59% 0.1 - 0.5 
Landfill gas plant 32 – 36%  0.75 - 8 
Landfill gas plant - 
CHP  
 31 - 35% 50 – 54% 0.75 - 8 
Sewage gas plant  
 28 – 32%  0.1 - 0.6 Biogas 
Sewage gas plant - 
CHP  
 26 – 30% 54 – 58% 0.1 - 0.6 
Biomass plant  
 26 – 30%  1 - 25 
Cofiring 37%   
Biomass plant - 
CHP  
 22 – 27% 63 – 66% 1 - 25 Biomass 
 
Cofiring - CHP 20% 60%  
Waste incineration 
plant  18 – 22%  2 - 50 Biowaste  
 
Waste incineration 14 – 16% 64 – 66% 2 - 50 
 
EN 57   EN plant - CHP  
Large-scale unit   89% 10 
Biomass - Medium-
scale unit   87% 5 Biomass 
district heating 
District heat Small-
scale unit  85% 0.5 - 1 
log wood  
  75 - 85% 0.015 - 0.04 
wood chips  
  78 - 85% 0.02 - 0.3 Biomass - 
residential  
heat pellets  85 - 90% 0.01 - 0.25 
 
 
EN 58   EN ANNEX III– Analysis of actions undertaken  to ensure sustainable production and 
consumption of biomass in different sectors  
In the last quarter centu ry a growing body of scientific resear ch has revealed that the world’s 
forests are under stress (BTG report, 2008). Voluntary measur es have been taken to combat 
deforestation. The following analyses the actions taken in the forest sector, as well as in 
agriculture and the energy sector.  
Forests:   
Numerous studies in the EU indi cate that there is a considerable potential to increase the use 
of forest products without harmi ng the forest environment (e.g. EEA, 2006)62. However, it is 
accepted that there might be the risk that curre nt voluntary initiatives (including certification 
schemes) do not cover all aspects arising from in tensified use of forests. In most EU Member 
States the forest law promotes the concept of sustainable forest management (SFM) as defined 
by the MCPFE process and further developed b y, among others, Criteria and Indicators for 
SFM (C&I) and the Pan-European Operational Le vel Guidelines (PEOLG). However, aspects 
such as intensive forms of forest harvesting or  balancing carbon stocks are not always covered 
by voluntary or national initiatives.  
There are also no assurances that countries  outside the EU appl y SFM principles and 
practices. The United Nations Forum on Fore sts agreed in 2007 a "Non-legally binding 
instrument on all types of forests", whose purpos e is to strengthen political commitment and 
action at all levels to implement effectively sust ainable management of all types of forests and 
to achieve the shared global objectives on forests. It  reiterates that each state is responsible for 
the sustainable management of its forests and for the enforcement of its forest-related laws, 
with four global objectives in mind:  
– Reverse the loss of forest cover wo rldwide through sustainable forest 
management, including protection, restora tion, afforestation and reforestation, 
and increase efforts to prevent forest degradation; 
– Enhance forest-based economic, social  and environmental benefits, including 
by improving the livelihoods of  forest dependent people; 
– Increase significantly the area of protect ed forests worldwide and other areas of 
sustainably managed forests, as well as  the proportion of forest products from 
sustainably managed forests; 
– Reverse the decline in official devel opment assistance for sustainable forest 
management and mobilize significantly in creased, new and additional financial 
resources from all sources for the im plementation of sustainable forest 
management. 
 
EN 59   EN There appears to be growing international consen sus on the key elements of sustainable forest 
management and seven common thematic areas81 of sustainable forest management have 
emerged in the UNFF document. 
However, the ten regional and international initia tives to put in place crit eria and indicators to 
monitor these developments82 have seen great variations. The Centre for International forestry 
Research (CIFOR) and the African Timber Or ganisation do not use the same criteria for 
evaluating the sustainable manageme nt of forest. The criterion re ferring to the maintenance of 
forest contribution to global carbon cycles is  only mentioned by the Montreal process, the 
Dry-Zone Africa Process on Criteria and Indica tors for Sustainable Forest Management, and 
the Pan-European Forest Process on Criter ia and Indicators for Sustainable Forest 
Management.  
Even within one regional initiative, the nationa l implementation of agreed principles varies 
widely. The Pan-European Operational Level Gu idelines for Sustainable Forest Management, 
endorsed by the Lisbon Ministeria l Conference on the Protection of Forests in Europe in June 
1998 and improved by the MCPFE expe rt level meeting in Vienna  in October 2002, are based 
on the following principles/ indicators: 
– Maintenance and Appropriate Enhancement of Forest Resources and their 
Contribution to Global Carbon Cycles (s uch as maintenance and enhancement 
of forest area, forest per capita, maintena nce of age structure and / or diameter 
distribution and carbon stock) 
– Maintenance of Forest Ecosystem Health  and Vitality (suc h as control of 
deposition of air pollutants, ma intenance of soil conditions)  
– Maintenance and Encouragement of Pr oductive Functions of Forests - Wood 
and Non-Wood (such as balance betw een net annual increment and annual 
felling of wood, quantity of marketed roundwood and non-wood goods) 
– Maintenance, Conservation and Appr opriate Enhancement of Biological 
Diversity in Forest Ecosystems (suc h as maintenance of tree species 
composition, maintenance of share of natural regeneration and share of planting and seeding and maintenance of naturalness of forest, protection of 
threatened forest species 
– Maintenance and Appropriate Enhancemen t of Protective Func tions in Forest 
Management (notably soil and water i. e. prevent erosion and protect water 
supplies 
– Maintenance of Other Socio-Economic  Functions and Conditions (such as 
contribution of forest sector to GDP a nd existence of occupational safety and 
                                                
 
81 Extent of forest cover, Biological diversity, Fore st health and vitality, Productive functions and forest 
resources, Socio-economic functions, Legal, po licy and institutional framework, Water and soil 
protection (protective functions) 
82 ITTO, Montreal Process, Regional initiative for th e development and implementation of national level 
criteria and indicators for the sustainable management of dry forests in Asia, African Timber Organisation, The Dry-Zone Africa Process on Criteria and Indicators for Sustainable Forest 
Management, Lepaterique Process of Central America, The Pan-European Forest Process on Criteria 
and Indicators for Sustainable Forest Management, The Near east process, CIFOR 
 
EN 60   EN health requirements and accessibility for recreation and maintenance of cultural 
and spiritual values 
As these principles are insufficiently precise to  serve as clear obligat ions, their application 
varies from region to regi on. The MCPFE is currently disc ussing possible options for a 
legally binding agreement on forests in the pan-European region, to strengthen the 
instruments to deal with new challenges for fo restry, including for climate change mitigation.  
As inter-governmental responses have been st rongly criticised and vo luntary certification 
schemes started to develop. Ther e exist a rather large range of  certification standards, but 
most have been endorsed either by the Programme  for the Endorsement of Forest Certification 
(PEFC) or the Forest Stewardship Council (FSC).  
The global area of certified forests covered 306.3 million hectares in June 200783 (Figure 1). 
This is more than double the level in 2002 but since 2005 the growth rate has been slowing. 
The annual growth rate has fallen by more than half to about 10% per year while the pre-2005 
rate was about 37% per year. 
Figure 1: Global Certified Forests 1994-2007 
050100150200250300350
94 95 96 97 98 99 00 01 02 03 04 05 06 07
(June)illi hmillion ha
 
Source: Indufor 
Table 9 shows that by the end of 2006 193.7 million ha (65%) of forest is certified by PEFC, 
84.2 million ha (29%) by FSC and 17 million ha (6%) by other systems (the American Tree Farm System, Malaysian Timber Certifica tion Council and the Dutch Keurhout system). 
Some of these schemes rely on inter-governmental principles such as the Pan European Principles for European Forests, the Montr eal Principles for other temperate and boreal 
forests, and the ATO/ITTO prin ciples for tropical forests). 
Table 10: Certified forest area by sc heme and region in December 2006 (million 
hectares)
84 
 North 
America South & Central 
America Europe Asia Oceania Africa Russia Total 
FSC 27.3 9.6 29.6 1.6 1.3 2.5 12.3 84.2 
                                                 
83 ITTO (2008) "Comparability and accepta nce of forest certification systems" 
84 Source: http://www.fores trycertification.info/ 
 
EN 61   EN PEFC 128.3 2.3 57.4   5.7     193.7
Othera 11.0     4.8   1.2   17.0 
Total 166.6 11.9 87.0 6.4 7.0 3.7 12.3 294.9
a Other in North America refers to American  Tree Farm System, in Asia refers to the 
Malaysian Timber Certification Council, in Af rica refers to areas in Gabon recognised under 
the Dutch Keurhout system 
In 2005, the total amount of forests worldwide was just under 4 billio n hectares, equal to 
about 30 percent of the land area on Earth (F AO, 2005). This shows that only around 7% of 
all forests are certified in the world. The tw o charts below show that certification is 
increasing, but mostly in North America and West ern Europe and in Europe the certification 
is much higher – and reaches 60 %.  
Chart 1: Change in certified forest area (global) 
 
Chart 2: Certified forest area by sche me and region in December 2006 (global) 
 
EN 62   EN 
 
The third chart shows that al most 60% of Western Europ ean forests are certified.  
Chart 3: Certified fores t area by region  
 
Total area of forest and other wooded land in  the EU is about 177 million hectares, which 
corresponds to over 37% of the to tal EU area. It is calculated  that annually the standing 
growing stock volume of wood in the EU fo rests grows by approximately 670 million m 3. 
Around 450 million m 3 of this wood every year is used fo r both industrial purposes as well as 
energy or other household needs. Roughly arou nd 60% of forests (excluding other wooded 
land) in the EU are under private ownership, while around 40% are publicly owned. The share 
of private ownership is very diverse among th e EU Member States. The highest share of 
 
EN 63   EN privately owned forests is in Portugal (92.7%), followed by Austria (80.4%), Sweden 
(80.3%), and France (74%). According to the COWI Consortium (2009), there are a total of 
10.7 million private forest holdings in the EU, and 77,000 public forest holdings. The average 
size of a public holding in the EU is about 1,200 ha  while the average size of a private holding 
is 10.6 ha.  
Agriculture:  Sustainability criteria in the Renewabl e Energy Directive are mainly focused on 
agricultural biomass in the EU, as biofuels for transport a nd bioliquids for heating and 
electricity are mainly produced from agricultur al feedstocks. In ge neral inside the EU, 
sustainable agricultural production is ensure d through tenforcing mandatory environmental 
standards and "cross-complian ce" in the Common Agriculture Policy which links income 
payments to farmers and the respect of thos e standards. In addition, common environmental 
rules (inter alia NATURA 2000, the water Framew ork Directive, Nitrat es Directive and EU 
legislation on Pesticides) apply to agriculture85. This impact assessment concerns solid and 
gaseous biomass for energy generation, and ther e is low likelihood of importing solid biomass 
or biogas from agricultur e from third countries.  
Energy sector:  
Some Member States are alread y developing sustaina bility requirements for bio-energy. As a 
result, energy companies have developed thei r own standards for complying with such 
requirements. The BTG 2008 study assessed certific ation systems of energy companies, such 
as the Essent Green Gold Label standard and Laborelec's Sustainability Certification.  
The Green Gold label uses forest ry certificates or agricultural certificates such as Organic, 
EUREPGAP or a ‘testimony of approval’ based on forest management criteria or agricultural 
source criteria based on the United Nations su stainable development program Agenda 21 
when no certification system is available. In the GGL Glossary86 a certification body is 
defined as ‘a third party certi fication company that is accred ited ISO 65 (or equivalent) for 
GGL and is approved by the GGL foundation’. Mo st of the companies selling biomass to 
Essent are using certification schemes to prove sustainabili ty. The Green Gold Label is 
establishing partnerships with emerging biom ass sustainability standards like the Dutch 
NTA8080 based on the Cramer Criteria. 
The Laborelec scheme was established in response  to Belgian law giving  support according to 
the sustainability and CO 2 balance of the supply chain. The system is based primarily on the 
FSC certification system, but also includes a GHG balance. The preferred types of biomass 
are residues from e.g. wood i ndustry or low value residues fro m food industry, but wood from 
short rotation plantations would also be accep ted. The Laborelec sustai nability certification 
requires a supplier declaration, international tr ansport declaration, overview of the energy 
balance, and an independe nt third party prepares  an audit report. Costs associated with the 
certification system are to less than € 0,5/tonne imported biomass (Ryckmans 2007)87. SGS is 
the sole independent body pe rforming verifications.  
                                                 
85 Note all short-rotation coppicing (S RC) is considered under agriculture , as some Member States include 
SRC in the agricultural sectors, while others in the forest sector 
86 GGL Glossary version 2005.2 See http://www.controlunion.co m/certification/ default.htm  
87 Ryckmans Y, Andre, N (2007) "Novel certification procedure fo r the sustainable import of wood 
pellets", Laborelec 
 
EN 64   EN Developments in other Member States, such as the Biomass E nvironmental Assessment Tool 
(BEAT)88 calculator in the UK, or the Cramer sta ndard in the Netherlands, could lead to 
industry in those countries de veloping new standards.  
Internationally, a labell ing scheme for sustainable bio-en ergy based on the Eugene standard89 
has developed, which requires comp lete FSC certificati on of wood energy crops, or that wood 
biomass comes from sustainably managed forest s, as defined by the label in a generic and 
sometimes more specific way. To verify claims , the national Eugene-accredited organisation 
must perform random checks of th e auditor’s work to ensure a sufficient degree of control. 
                                                 
88 www.biomassenergycentre.org.uk/BEAT 
89 www.eugenestandard.org 
 
EN 65   EN Annex IV: Member countries of the major inter-governmental organisations and 
processes or initiatives relevant to crit eria and indicators for sustainable forest 
management  
ITTO  Consumers:  
Australia, Canada, Ch ina, Egypt, European 
Community, Austria, Belgium, Luxembourg, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Netherlands, Poland, Portugal, Spain, Sweden, United Kingdom, Japan, Nepal, New Zealand, Norway, Republic of Korea, Switzerland, United States of America 
Producers:  
Cameroon, Central African Republic, Congo,Côte d'Ivoire, Democratic Republic of the Congo, Gabon, Ghana, Liberia, Nigeria, Togo, Cambodia, Fiji, India, Indonesia, Malaysia, Myanmar, Papua New Guinea, Philippines, Thailand, Vanuatu, Bolivia Brazil, Colombia, Ecuador, Guatemala, Guyana, Honduras, Mexico, Panama, Peru, Suriname, Trinidad and Tobago, Venezuela 
Montreal Process  Argentina, Australia, Canada, Chile, China, 
Japan, Republic of Korea, Mexico, New Zealand, Russian Federation, Uruguay and USA  
Regional initiative for the development and 
implementation of national level criteria and indicators for the sustainable management of dry forests in Asia Bangladesh, Bhutan, Ch ina, India, Mongolia, 
Myanmar, Nepal, Sri Lanka, and Thailand  
African Timber organisation A ngola, Cameroon, Central African 
Republic, Congo, Cote-d'Ivoire, Democratic Republic of Congo, Equatorial Guinea, Gabon, Ghana, Liberia, Ni geria, Sao Tome et 
Principe and Tanzania  
The dry-zone Africa process on Criteria and 
indicators for Sustainable forest management  Burkina Faso, Cape Verde, Chad, Gambia, 
Guinea Bissau, Mali, Ma uritania, Niger and 
Senegal. IGADD (7): Djibouti, Eritrea, 
Ethiopia, Kenya, Somalia, Sudan, and Uganda. SADC (14): Angola, Botswana, Democratic Republic of Congo, Lesotho, Malawi, Mauritius, Mozambique, Namibia, 
Seychelles, South Africa, Swaziland, 
Tanzania, Zambia, Zimbabwe  
 
EN 66   EN Lepartique Process of  Central America on 
Criteria and Indicators for sustainable forest 
management Belize, Costa Rica, El Salvador, Guatemala, 
Honduras, Nicaragua and Panama  
The Ministerial Conferences for the 
Protection of forests in Europe, Pan-European Forest Process on Criteria and indicators for sustainable forest Management  Albania, Austria, Belarus, Belgium, Bosnia-
Herzegovina, Bulgaria, Croatia, Czech Republic, Denmark, Estonia, European Community, Finland, France, Georgia, 
Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechte nstein, Lithuania, 
Luxembourg, Monaco, Netherlands, Norway, Poland, Portugal, Romania, Russian Federation, Slovak Republic, San Marino, Slovenia, Spain, Sweden, Switzerland, Turkey, Ukraine, United Kingdom and Yugoslavia  
The Tarapoto Proposal of Criteria and 
indicators of the Amazon forest  Bolivia, Brazil, Colombia, Ecuador, Guyana, 
Peru, Suriname and Venezuela  
The Near East Process  Afghanista n, Algeria, Azerbe ijan, Bahrain, 
Cyprus, Djibouti, Egypt, Islamic Republic of Iran, Iraq, Jordan, Kuwait, Kyrgyz Republic, Lebanon, Libya, Malta, Mauritania, Morocco, Oman, Pakistan, Qatar, Kingdom of Saudi Arabia, Somalia, Sudan, Syria, Tadjikistan, Tunisia, Turkey, Turkmenistan, United Arab Emirates and Yemen  
CIFOR  Australia, Austria, Belgium, Bolivia, Brazil, 
Brazil, Cameroon, Canada, China, Costa Rica, Cote d'Ivoire, Finland, France, Gabon, Germany, India, Indonesia, Japan, Malawi, Malaysia, Mexico, Nepal, Netherlands, Philippines, South Africa, Sweden, Tanzania, Thailand, United Kingdom, USA, Zambia, Zimbabwe  
 
EN 67   EN  
ANNEX V – GHG methodological questions  
This annex describes in more detail the c hoices made for the methodology. The choices are 
guided by some general principles concerni ng how the methodology should be developed: 
– The methodology should be robust to changing the product in question, i.e. it can be 
used in other fields/sectors  without much modification 
– Takes into account the whole pathway from "cradle to grave", in this case from 
energy source to final energy 
– Scientifically sound 
– As simple as possible, although s till being scient ifically sound 
– Robust in terms of assumptions on a EU-w ide scale, avoiding regional differences, 
and avoiding the possibility of multiple interpretations of assumptions 
– Works in a policy-context i.e. helps to fu lfil the objectives of the policy in question. 
The Renewable Energy Directive re quires Member States to have a certain percentage of final 
energy as renewable energy in transport and in the energy system as a whole. The GHG-
methodology laid down in the RES Directive thus  follows the energy chain from source to 
final energy, which in the case of transport means as final fu el. In the case of heating and 
electricity the final energy is electricity and heat, which implies that end-conversion 
efficiency should be included in the calculations if  the life cycle assessment is to be carried 
out on the basis of final energy. An alternativ e is to calculate th e GHG emissions only until 
the production of the fuel, e.g. biomass pellet s, chips, charcoal et c, not reflecting its 
conversion to electricity and heat . These two options are consider ed in the analysis below.  
The discussion then turns to the determination of fossil fuel comparator, which is closely 
interlinked with the first issue. The third sec tion analyses five differe nt ways of allocating 
between heat and other energy ca rriers. The last part of th is annex discusses necessary 
amendments of the greenhouse gas methodology as laid down in the Renewable Energy 
Directive, for solid and gaseous biomass us ed in electricity an d heating/ cooling. 
V.1 Inclusion of end conversion efficiency  
The GHG emissions from heat and electricity  made from biomass is dependent on both 
upstream cultivation, processing etc. but also on end conversion. The e fficiency of different 
technologies converting biomass to  heat, electricity or both vary  to a large extent, from 10 – 
15 % for small electricity plants to 85-95 % fo r large scale CHP plants. There are thus large 
differences between technologies, but also within  one technology cluster. An example of this 
is provided in Figure 2, where the electric effi ciency as a function of capacity is shown for 
different CHPs (based on Ecorys, 2009): 
Figure 2: Electric efficiency for differen t CHPs as function of power output 
 
EN 68   EN 
 
The same is the case for electricity-only plants, which vary the most according to whether it is 
a steam cycle, gas engine or diesel engine etc.  End-conversion can vary considerably, but it is 
not evident that the only way of addressing  the end-conversion efficiency is through its 
inclusion in the GHG calculation. However as the RES Directive sets targ ets for each Member 
State on the basis of final energy consumption, this coul d be a natural conclusion, and 
principle nr.2 above favours taki ng the whole chain into account. This aspect is discussed in 
the section below.  
Cradle to fuel, or cradle to final energy, alternative A or B 
There are two main options for GHG calculation of biomass pathways 
(a) Analysing the chain from "cradle to gate", i.e. from cultivation to fuel 
(b) Analysing the whole chain from "cradle to final energy", i.e. from cultivation 
to final energy, including end use efficiency 
The choice is to analyse the issue of allocation and fossil fuel comparator without or with the 
end-conversion efficiency included (alternat ive A or B), as indicated in Figure 3. 
Figure 3: Depiction of alt ernative A or B for calculat ing emissions from biomass 
pathways 
 
 
EN 69   EN The choice between alternative A or B influences both choice of fossil fuel comparator and 
how e.g. heat is taken into account90. 
Alternative B is in fact much more complicat ed as both the efficiency of the bioenergy 
process as well as that of the fossil fuel comparat or has to be taken in to account, as indicated 
in Figure 4 below. Apart from the question of  what impacts this option would have in 
practice, it will be important to consider wher e the data on efficiency for this option would 
come from, particularly where it concer ns a decentralised sector as heat. 
Figure 4: Depiction of alternative B 
 
 
The resulting GHG savings (S) is then derived by the following formula, where the fossil fuel 
comparator (FFC) is compared with the GHG emissions.  
baPbPa ba
baFFCGHG FFCS
,, ,
,−=  
Alternative A is similar to existing RES Directive where it concerns bioliquids91. The 
downside is that low end conversion of bioma ss will not be included in the GHG claims, and 
most variation between biomass pathways lies in  the end conversion efficiency, especially for 
smaller units. Alternative B will include end conve rsion efficiency and thus be more holistic 
than alternative A. However, alternative B may onl y incentivise higher effi ciency if there is a 
bonus for lower emissions, or if higher effici ency can raise a certa in pathway above the 
threshold if such a threshold is applied. 
It will be difficult to apply alternative B to  all biomass use, as e.g. demanding GHG claims 
from households would be an excessive admini strative burden. Higher end use efficiency for 
small units might be obtained more effectivel y by labelling or other measures targeted at 
households and other small scale utilisa tions. Alternatively, the methodology may be 
differentiated for scale, i.e. applying alternativ e A for small scale utilisation and alternative B 
for large scale plants above a certain threshold. 
                                                 
90 Heat is not considered a co-product in the Renewable Energy Directive where it concerns biofuels and 
bioliquids. 
91 For biofuels alternative A and B work out in principle the same, since the end use efficiency of biofuels 
and their fossil fuel alternatives is the same. The Renewable Energy Directive uses alternative A for 
biofuels, although it allows alternative B is evidence is provided. 
 
EN 70   EN V.2 Fossil fuel comparator 
The choice of alternative A or B is influenced  by decisions on fossil fuel comparator, as well 
as how heat is taken into account, and should thus not be concluded in isolation. These 
aspects are discussed below.  
There are several methodological choices to ma ke, in order to calculate the fossil fuel 
comparator for heat and electricity, related to compared technology and geographical scope. 
The substituted heat and/or electricity is hi ghly dependent on local/r egional conditions, like 
what types of fuels are availabl e, biomass prices, technology choices etc. The choice is also 
dependent on whether one chooses alternative A or B, regarding inclusion of end use 
efficiency. If option A is preferred, it makes sense to take into account both heat and 
electricity in the comparator, since the fuel wi ll be used for both. If option B is chosen one 
already knows the end energy service, and it is  therefore more sensible to apply respective 
fossil comparators for heat and electricity.  
In general the question of fossil fuel compar ator can be dealt along two axis; geographical 
scope and end-use (electricity or heating or cogeneration). 
Three options exist on geographical scope: 
• EU wide comparators 
• National comparators 
• Regional comparators 
Options for end-use types: 
• One single comparator irrespective of the use (biofuels, heat, electricity, CHP)  
• One single comparator to  cover both heat and electricity respectively 
• One comparator for each main technology clus ter; heat plants, electricity plants 
and CHP (this is the approach in the Directive currently for bioliquids). 
For certain options choices have to be made on whether to choose av erage or best practice 
technologies, and how to weight electricity vs. he at for CHP.  
Geographical scope 
The Renewable Energy Directive applies an EU wi de comparator as the fossil fuels used for 
transport are traded easily thr ough Europe. It follows the same approach for bioliquids. The 
question is whether this approach  should be used in general wher e it concerns electricity and 
heat or whether national or re gional comparators shoul d be used or allowe d. These latter seem 
however to run into undesired effects as the diffe rent fossil fuel mixes and thus their potential 
comparators used in different Member States or regions would render the exact same biomass 
as sustainable in one country, but unsustainable in another. This is shown in Figure 5, where 
the heat mix of different nations is displayed in terms of the fossil fuel comparator. It is clear 
that in such a context certain biomass could be  regarded as sustainable in Poland, but not in 
France or Germany. Such an approach would be su itable if biomass was not trade-able across 
 
EN 71   EN regions or nations. However it is trade-ab le and such measures could create market 
distortions. 
Figure 5: Effects of national  Fossil Fuel Comparators  
Fuel basis (alt. a) FFC H
020406080100120140
1FFC [g CO 2eq./MJ fuel]
France Germany Poland
 
The savings from using e.g. soybean  oil would be different in a country mainly using gas as a 
source of heat compared to a country using coal. This is shown in the Figure 6, where 
soybean GHG-savings on a fuel-basis is shown fo r different fossil fuel comparators for gas, 
coal and three countries, and regardless of end use. 
Figure 6: GHG emissions savings on fuel basis 
Emission saving on fuel basis [%]
0%10%20%30%40%50%60%
1Fossil EU27 Coal Gas France Germany Poland
 
Use of soybean would thus lead to 46 % sa vings in France and 58 % in Germany, which 
might be unjustified in reality when one is looki ng at the actual heat-ins tallations. While it can 
be argued that such differentiation could be just ified as the fossil fuels replaced are different 
and the biomass should be used in those regions where it replaces the most GHG burdensome 
 
EN 72   EN fossil fuels, it is not possible to say that this would actually happen in pr actice. It can usually 
not be known what specific fossil would be repl aced and e.g. heat is often utilised in stand-
alone systems where there is no marginal heat source as such. The electricity use pulls energy 
from a common pool (i.e. all electricity produc ers connected to the grid), where one can 
clearly consider a physical shor t-term substituting effect; this principle does not apply to the 
heat sector, where systems are highly diversif ied and decentralised. Besides; the national 
statistics for heat are often poor and different methodologies are applied in different countries. 
It would therefore be necessary to improve heat statistics in order to establish credible 
comparators. In sum, it is submitted that EU-wide fossil fuel comparators for different 
technologies should be used, which follows from principles 5. and 4. (robust assumptions and 
simple methodology).  
End-use types alternative A  
The simplest option is to apply one single compar ator irrespective of the use (biofuels, heat, 
electricity, CHP). This would prevent that the bi omass is diverted to a specific sector where 
the fossil fuel comparator is more favourab le. Although that may act ually lead to higher 
greenhouse gas savings, there is no guarantee  that this will happen and it would not 
necessarily reach the objectives of renewabl e energy policy in a more cost-effective way. 
Since a comparator for biofuels is already we ll established, it would seem this comparator 
should be taken in such case, wh ereas it has no particular rele vance or relati on to heat or 
electricity. This would also deviate fro m the approach taken for bioliquids. 
The other two options are very si milar to each other and the main question is how to take into 
account CHP. The first option is simply to have a comparator for heat and one for electricity 
as those are already in th e Directive for bioliquids: 
Heat: 77 g CO 2eq/MJ fuel 
Electricity: 91 g CO 2eq/MJ fuel 
A separate comparator could be given for CHP as is in the Directive for bioliquids. 
CHP: 85 g CO 2eq/MJ fuel 
However, when end conversion efficiency is not taken into account the result is that CHP 
comes with the current numbers out worse th an stand alone electricity, which may give 
undesired consequences. An example would be e.g. the use of ethanol from wheat (lignite as 
process fuel). If it is used in an electricity pl ant it just makes the threshold with savings of 38 
%, but in a CHP the savings ar e only calculated to be 33 %,  and thus below the threshold. 
However, in reality, the CHP saves consider ably more GHG emissi ons, because of much 
higher efficiency, but the incentives here enco urages the option with the least savings.  
Alternatively, a comparator for the CHP can be obtained in different way, even without 
completely taking into account the efficiency of the end use conversi on. The alternative fuel 
use formula based on the CHP Directive could be taken as a basis to calculate the comparator, 
which follows the logic of the alternative fuel use methodology; taking into account the 
amount of biomass that would be needed in orde r to obtain the same amount of electricity and 
heat if it was produced in separate plants. Th e fossil fuel comparator (FFC) for CHP is thus 
obtained through the following formula: 
 
EN 73   EN FFC CHP = FFC e* ηe/ ηe0 + FFC h*ηh/ ηh0 
Where: 
• ηe and ηh are the electrical and thermal efficiency of the CHP plant, here assumed to be 25 
% and 60 %, for electricity and heat respectively. 
• FFC e and FFC h are the Fossil Fuel Comparators for elect ricity and heat (given as 91 and 77 
g CO 2eq/MJ) 
• ηe0 and ηh0 are reference values for the efficienci es of uncoupled generation of electricity 
and heat, for which in this case is suggested to  be 33 % and 86 %, which is for solid wood 
fuel taken from annex I and II of the CO M decision 21/XII/2006; reference values for 
separate production of electricity and heat in  application of the CH P-directive (2004/8/EC). 
This example would result in the following FFC: CHP: 123 g CO
2eq/MJ 
The main disadvantage with this option is that it is still static: it disregards the different 
heat/electricity ratios for individual CHP insta llations, which in fact is a problem for all 
"alternative A" solutions where the emissions ar e accounted for the fuel, and not for the final 
energy. This would not encourage more efficient use of biomass, and as such be in breach 
with the 6. principle (contributing towards the policy objectives).  
Biomass end conversi on, alternative B 
The analysis now looks at alternative B, as shown in Figure 7. This  implies that the end-
conversion efficiency is taken into account bot h for the fossil fuel comparator (FFC) and the 
actual biomass pathway i.e. what are downstrea m emissions of the biomass fuel when it is 
converted to final energy or other biomass ba sed energy carriers (such as biofuel). This 
implies a wider assessment of the allocation be tween electricity, heat and eventually other 
products.  
Figure 7: Depiction of Alternative B 
 
The outcome of the analysis of national or regional FFC unde r alternative a,  applies to 
alternative b as well, thus is EU-wide FFC a ppropriate. The remaining option regards end use 
technologies and how to determine the FFC. 
Options for end-use types: 
 
EN 74   EN • One common FFC for heat, CHP and electricity. 
• One comparator for each main technology cluster;  heat plants, electric ity plants, bioenergy 
plant92 and CHP  
• One FFC for heat and electricity respectively. 
• One FFC for a range of possible products and energy carriers; su ch as biofuel, chemicals, 
electricity, heat etc.  
For certain options choices have to be made on whether to choose av erage or best practice 
technologies, and how to weight electricity vs. he at for CHP.  
The first option disregards the different effici encies and utilities of technologies and energy 
carriers. The FFC for heat would be the same as for electricity alt hough emissions stemming 
from a unit of fossil electricity are considerably higher than from  a unit of fossil heat. Such an 
option would neither represent reality nor give desirable incentives, and be in breach with the 
principles 6. as well as 3. This option is thus discarded.  
The second option takes into account different  technologies, but does not regard the 
differences within a technology cluster, wh ich is especially relevant for different 
heat/electricity ratios for CHP. In such a cas e a CHP with only a sma ll amount of electricity 
produced obtain the same FFC as a CHP with mu ch more electricity produced. This does not 
give the right incentives, as electricity has a higher value than heat, and generally a higher 
GHG intensity. The second op tion is thus discarded. 
The third option reflects the alternative fossil pr oduction of heat and electricity for all heat-, 
electricity-, and CHP-te chnologies with different  heat/electricity ratio s, and integrates the 
difference between electricity and heat in a re alistic manner in contrary to the two first 
options. The fourth option builds on the third op tion, but includes also biomass products other 
than heat and electricity. Under this option the FFCs would represent their fossil substitute, 
including for chemicals and proc ess-industry feed stocks. The FFC s of the latter two would be 
as a function of the carbon c ontent of their fossil substitute s. Possible problems could occur 
from bio-chemicals that can have  a range of utilisati on, all with different carbon savings. This 
can be solved by attributing a distinct FFC to  groups of products. The simplest and perhaps 
the option that would be most appropriate in  the beginning is one FFC for chemical bio-
products. In total this would then  lead to four FFCs: biofuel, heat, electricity and chemicals. 
The main issue with this option is the in troduction of FFCs for commodities other than 
energy, and thus going beyond the purpose of this report. 
To see how the FCC inflects the GHG performance of differe nt technologies, one has to 
decide the weighting between di fferent energy carriers, in the case of CHP: electricity and 
heat. This is discussed in  the following section.  
                                                 
92 A bio-energy plant is here a plant which uses biomass as feedstock, and produces various energy 
carriers and or products, like biofuel,  chemicals, electricity, heat etc 
 
EN 75   EN V.3 Biomass end conversion, alternative B: Allocation between co-products for heat 
and other energy carriers  
The discussion concerning which way to attribut e upstream emissions to end products in case 
of combined heat and power (CHP) is best show n with an example. The basic question is how 
the up-stream emissions should be divided between the end pr oducts. Since e.g. electricity 
and heat have different utilisa tion possibilities and co sts, it is not obvious that a simple energy 
allocation is sufficient. The al ternatives analysed are:  
– Exergy allocation 
– Energy allocation 
– Economic allocation 
– Alternative production allocation 
Finally, a fifth method for accounting for emi ssions between different co-products (the 
"energy allocation with common indicator") is an alysed at the end. It differs from the above 
four alternatives, as one emission value is calculated for all products , and no allocation is 
taken place between the end products. 
In this first example the CHP is producing with an  overall efficiency of 90 %, of which 1/3 is 
electricity and 2/3 is heat (hea t to electricity ration of 2). Th e resulting emissions for soybean 
as feedstock are shown in Figure 8, where 1 MJ of soybean is fed into the CHP, and it is 
producing 0.3 MJ electric ity and 0.6 MJ of heat. 
Figure 8: Emissions from soybean in cogenerati on dependent on method of allocation of 
emissions between heat and electricity 
Final energy basis
0102030405060708090
Exergy allocation Energy allocation Economic
allocationAlternative
productionGHG emissions [g CO2-eq. /MJ]
Electricity Heat
 
 
EN 76   EN The exergy allocation is assuming ambient temper ature of 0 °C, and heat delivered at 120 °C. 
This assumption is further discussed below. Th e electricity is assumed to have 100 % exergy. 
It is clear that the higher exer gy content of electricity have to  bear more of the emissions. The 
allocation is based on the carnot  efficiency, or the thermodynamic quality of the heat;  
henv h
TTT−=η  
Where T is measured in absolu te temperature (Kelvin), and T h is the temperature of the heat 
and T env is the temperature of the environment, or  surroundings, set at 0 °C or 273 Kelvin. 
The allocation based on economic valuation uses average prices in EU25 2004 – 2007 for 
large industries, and heat deliver ed with natural gas (n = 90%)). This results in prices of 18.3 
and 6.6 €/MJ for electricity and heat respectively. The economic  and exergy allocation shows 
similar patterns and values, while alternative production allocation show s the same pattern as 
exergy and economic allocation, bu t with less difference between  heat and electricity, all 
indicating that electricity has a higher value than heat. The energy allocation does not take 
this into account and allocate s the emissions solely regardi ng energy content, not having 
regard to available work (exergy), market value (economic allocation) or alternative 
production of heat and electricity.  
It is clear how all the allocation methods, excep t energy allocation, hold the electricity more 
responsible for the emissions, than the heat. Wh en these numbers are further combined with 
fossil fuel comparators (FFC) for EU27, for electricity and heat respectively, the GHG-
savings are obtained, as shown in Figure 10. The FFC are 198.4 g/MJ for electricity and 87.3 
g/MJ for heat, and are based on the fossil mix of electricity and heat in EU27. For cooling the 
FFC is set to 57 g/MJ; which is based on the FFC for electricity, but adjusted for a coefficient 
of performance (COP) of 3.5. The COP depends mainly on the temperature difference, and 
will thus vary according to climate and cooling demands.  
It is to be observed how th e FFC of heat and electricity balances the GHG-savings results 
compared to the emission intensity as shown a bove. Electricity obtains a larger FFC, and thus 
a larger (than heat) saving per MJ substituted.  
Figure 9: GHG savings of electricity and heat  in cogeneration, using different emissions 
allocation methods  
 
EN 77   EN Final energy basis
0%20%40%60%80%100%
Exergy allocation Energy allocation Economic
allocationAlternative
productionGHG savings [% ]
Electricity Heat
 
The resulting savings  show a rather wide sp read, as function of a llocation method, but with 
values in the same range for all allocation methods except en ergy allocation, with Exergy and 
Economic allocation showing very similar result s. One of the determining factors for which 
allocation method to apply is how  the allocation method is valui ng different heat/electricity 
ratios, and what kinds of "border-effects" to e xpect when the assumptions are more extreme. 
Figure 10 below compares the CHP from the exam ple above (total efficiency of 90 % and 
heat/electricity ratio of 2) with a CHP with tota l efficiency of 90 % and heat/electricity ratio 
(r) of 17, implying an electricity efficiency of 5 % and a heat efficiency of 85 %. 
Figure 10: GHG savings from two cogeneration pl ants with different efficiencies for heat 
and electricity conversion  
 
EN 78   EN Final energy basis
0%20%40%60%80%100%
Exergy allocation Energy allocation Economic
allocationAlternative
productionGHG savings [% ]Electricity (r=2) Heat (r=2)
Electricity (r=17) Heat (r=17)
 
It is evident how the ch ange in heat/electricity ratio ( r), changes the GHG-savings downwards 
for all allocation methods except for energy allo cation for which they remains constant. This 
implies, in the case of energy allocation that e .g. a MJ of electricity from a soybean fed CHP 
with low electricity production has the same savings as for a MJ fr om a soybean fed CHP 
with higher fraction of electricity production. In teresting is also the high savings obtained 
from electricity in the case of high productio n of heat (85%) for "alternative production" 
allocation. This stems from the methodology, wh ich is not suitable for CHP solutions with 
rather low fraction of electrici ty production (or heat  production). There is  a major drawback 
with this allocation method, and reason enough to discard the "alternative production" 
allocation method. 
A further factor that sheds li ght into the issue of allocati on methodology is the valuation of 
heat temperature. Economic allocation would mana ge to account for this, but with difficulties 
finding data, as there are no disa ggregated heat markets for diffe rent temperatures, and would 
thus practically lead to rather arbitrary a llocation numbers. Energy al location does not make 
any difference between 1 MJ at 10 °C or 1 MJ at 1000 °C, nor doe s the alternative allocation 
method. The heat temperature is an  important parameter, as it determines the amount of heat 
that is possible to convert to wo rk. Heat of higher temperature ha s a higher utility, as the heat 
can be converted to other form s of energy than thermal energy (namely work). However, this 
conversion is limited by the carnot efficien cy, mentioned above, and repeated here: 
henv h
TTT−=η  
Where T is measured in absolu te temperature (Kelvin), and T h is the temperature of the heat 
and T env is the temperature of the environment,  set at 0 °C or 273 Kelvin. The carnot 
efficiency, or the exergy content of the heat, is a simple physical measure of the potential 
 
EN 79   EN utility of heat, and thus useful as an instrume nt to differentiate between heat of different 
temperature. For the purpose of calculating the carnot efficienc y, it is assumed that 0 °C, or 
273 Kelvin, is the ambient temperature througho ut EU, in order to keep the simplicity.  
For heat of temperature lower than 150 °C it is  assumed a constant carn ot efficiency equal to 
that of 150 °C or 423 Kelvin (approximately  0.35). This is on orde r to avoid very low 
allocation values and confusion within the di strict heating sector, where most operators 
deliver heat at less than 150 °C. The price of for low-temperature heat is in the area of 1/3 of 
the price of electricity on an EU average leve l, and gives and additional argument for keeping 
a constant Carnot efficiency for this heat mark et. A price difference of 1/3 is very similar to 
the Carnot efficiency of heat  delivered at 150 °C (approximat ely 0.35). For the heat of higher 
temperatures there are few statistics on prices, as mentioned, so the Ca rnot efficiency is 
applied directly as allocation factor. The propos ed correlation factors are shown in figure 11, 
together with the Carnot efficien cy for the whole temperature range. 
Figure 11: Correlation factors for Carnot e fficiency for the whol e temperature range  
0,000,200,400,600,801,00
0 250 500 750 1000 1250 1500 1750 200 0
Heat T (Cels ius )Carnot efficiency
Carnot efficiency
Heat temperature allocation factors
 
Applying this method of allocati on introduces an important aspe ct of energy efficiency, as 
more efficient use of the ener gy sources is incentivised thr ough a realistic representation of 
the different utility of heat at different temper ature. This is especially relevant for high 
temperature heat demands in the industrial sect or, where heat delivery at higher temperature 
often comes at the cost of lower overall energy e fficiency. In order to exploit the potential use 
of CHP in industrial usage, it should not be a drawback for the operator to deliver demanded 
high temperature heat compared to delivering low temperature h eat, where the latter often can 
be done with higher overall ener gy efficiency, although with lo wer exergetic efficiency. The 
consequence of the proposed allocation is more GHG emissions attributed to higher 
temperature heat, and thus less to the co-generat ed electricity. A CHP delivering final heat at 
200 °C (with energy effici ency of 0.5) would have the same  GHG intensity of its electricity 
 
EN 80   EN (energy efficiency of 0.3) as a CHP with half the electricity efficiency  (energy efficiency of 
0.15), but delivering the same amount of heat  at 700 °C, everything else constant.  
Common GHG indicator 
An issue with the allocation approach is that a plant may produce electricity with GHG-
savings above the eventual threshold, but anot her co-product e.g. the biofuel, might fall 
below. To avoid this, it is necessary to develop a methodology for a common GHG-saving for 
the whole range of products. Th e easiest way of doing this is attributing one GHG-value to all 
products from one facility based on the weighting of the FFC for the different products, i.e. all 
emissions from the plant are attributed to all products, comparing with a weighted fossil fuel 
comparator, which is weighted according to the displaced products.  
For a CHP this would lead to the same saving for both the heat and th e electricity produced, 
but the more electricity produced, the more savings, as the FFC fo r electricity is considerably 
larger than for heat. The basis of the met hodology thus becomes a question of what products 
that are replaced and what savings this brings. For a CHP the FFC is given by: 
FFC CHP = FFC e* ηe/(ηe + ηh) + FFC h*ηh/(ηe + ηh) 
For different heat and electric ity efficiencies the total savings will vary according to the 
replaced fossil energy. The example provided here  is pure palm oil, as shown in Figure 12. 
The x-axis is electrical efficiency together with heat efficiency in descending order so that for 
the CHP the total efficiency is 0.85. For compar ison is also the heat - and electricity-only 
plants shown as function of th eir respective efficiencies. With  this methodology the electricity 
only plant needs an efficiency of around 55 % in order to give the same savings as the CHP 
with 35 % and 50 % electricity and heat efficiency respectively (the point far to the right for 
the CHP). 
Figure 12: Heat and electricity efficiencies as a f unction of GHG savings (based on palm 
oil) 
-60%-40%-20%0%20%40%60%80%
Heat 0,85 0,8 0,75 0,7 0,65 0,6 0,55 0,5
El. 0 0,05 0,1 0,15 0,2 0,25 0,3 0,35Heat and electricity efficiencyGHG savings [%]
CHP
Electricity-only
Heat-only
 
 
EN 81   EN For cases where no FFC is available for some of  the products (e.g. bio- refineries), the energy 
allocation between products will be used, and the portion of the products  with available FFC 
will be given the weighted common FFC. The sa me figure applied to waste wood as source 
gives the same pattern, but at much hi gher savings, as shown in Figure 13. 
Figure 13: Heat and electricity efficiencies as a f unction of GHG savings (based on waste 
wood) 
80%85%90%95%100%
Heat 0,85 0,8 0,75 0,7 0,65 0,6 0,55 0,5 0,45 0,4 0,35 0,3
El. 0 0,05 0,1 0,15 0,2 0,25 0,3 0,35 0,4 0,45 0,5 0,55Heat and electricity  efficiencyGHG savings [%]CHP
Electricity-only
Heat-only
 
Note that the numbers for CHP ends at 0.5 an d 0.35 as this is assumed to be the maximum 
power to heat ratio with still a total efficien cy of 85 % (assuming that higher efficiency for 
electricity requires a lower back-pressur e, and thus less recoverable heat). 
This method of weighted FFC applied to the ex amples given further up is summed up here 
(the soy CHP and third genera tion plant). The CHP fired with  pure soy, which achieves 78.3 
% and 50.7 % savings for electricity and heat (with energy allocation) , obtains a saving of 
65.4 % for both the heat and the electricity. This  result is lowered to 53.9 % when the power 
to heat ratio is lowered, and onl y 5 % electricity efficiency is assumed (same total efficiency 
of 90 %). This shows how the weighted FFC me thod incorporates the strength of economic-, 
exergy- and alternative production allocation with out being equally complicated. With energy 
allocation no credit is given for higher portion el ectricity produced, as one recalls from Figure 
13. The third generation plant that  produces electricity, heat a nd biofuel obtains a saving of 
92.6 % for all the products, instead of 96.2 % for electricity, 91.1 % for biofuel and 91.4 % 
for heat (energy allocation).  
The methodology would be expressed as follows , where a process have n different products, 
and each of them are produced in fraction f i and each product i has a FFC of FFC i: 
FFCGHG FFCSemissions−=  
Where: 
∑⋅=n
ii iFFCf FFC  
 
EN 82   EN With EU27 average and assumed efficienci es as in the CHP directive, the FFC i for heat is 
87.3 [g/MJ], electricity; 198.4 [g/MJ]. 
Summary of the discussion of choice of allocation method 
The exergy allocation has its main advantage of expressing a physical unit that relates to how 
much "work" the energy can deliver, and is in that regard accurate and correct way of 
expressing the value or utility of heat of diff erent temperatures. However; there are limitations 
regarding methodology, as there are uncertainties regarding how  to calculate the exergy 
content of e.g. biofuel. It would be possible to determine an academically correct way of 
calculating the exergy content, bu t it would still be difficult to ensure that the methodology 
would be put in place correctly all over EU, as  knowledge of exergy is limited. An alternative 
is to use exergy content only for heat, as the main concern is the allocation in the case of 
CHP. But still it would be difficult to determine how to set the temperature of the delivered 
heat and ambient temperature. Especially the first factor is possible to discuss at length. Is it 
the temperature at the conversion from energy carrier to energy servi ce, or at the system 
boundary of the CHP? The conclusion here is th e term "final energy" as defined in the 
Renewable Energy Directive (Direct ve/2009/28), and further used in  this report, i.e. "energy 
commodities delivered for energy purposes". This would thus be at the point of delivery. 
Energy allocation has its main disadvantage in its ignorance for the different value of different 
energy carriers and heat temperatures. The energy allocation is simple and applicable to most 
end products that might be produced even in bio -refineries as well, but does not represent the 
thermal physical laws, or the differentiate d economic valuation of heat at varying 
temperature. 
Economic allocation has its disa dvantages related to the ch anging behaviour of prices, 
together with difficulties of choosing the right price, regarding taxing-, subsidising- schemes 
across different countries and regions.  This option is thus discarded.  
The alternative production allocation works we ll, and shows similar allocation pattern as 
economic and exergy allocation. The main di sadvantage is the need for determining 
"alternative efficiencies", and espe cially in the case of more comp lex bio plants (refineries) It 
has also been shown that it is not suitable fo r not so common CHP configurations, with e.g. 
very low electricity efficiency. The altern ative allocation method is thus discarded. 
In order to avoid having di fferent saving numbers for diffe rent products coming from one 
production facility, it is desirabl e to obtain one figure for all the products. All the options 
above result in one figure for the heat and anot her figure for the electricity coming from the 
CHP. The fifth alternative (energy alloca tion with common GHG indicator) avoids the 
difficulties in allocating emissions to different  energy products. The main downside with this 
option is that it requires fossil fuel comparators fo r determining the results,  and is thus not in 
line with the principle of applying a holistic  methodology that might be applied in other 
sectors; in many sectors, like e.g. for the food a nd drinks, it would be illogical to have a fossil 
fuel comparator as in integral part of dete rmining the GHG emissions, this would be in breach 
with the second principle for a sound met hodology. This option is thus discarded. 
Conclusion 
For simplicity and coherence with the Renewabl e Energy Directive, energy allocation is kept 
for all allocation issues, except where heat is co-produced with other energy commodities. In 
 
EN 83   EN such a case; other energy commodities are give n an allocation factor (exergy content) of 
100%, while the heat is attributed according to its temperature at delivery point, using the 
Carnot efficiency.  
The equations necessary to describe th e methodology is presented in section V.4. 
V.4 Equations describing the methodology 
Greenhouse gas emissions from the production of solid and gaseous biom ass fuels, before 
conversion into electricity and/ or hea ting and cooling, sha ll be calculated as: 
E = e ec + e l + e p + e td + e u - e sca– eccs - e ccr, 
where 
E = total emissions from the use of the fuel before energy conversion; 
eec = emissions from the extraction or  cultivation of raw materials; 
el = annualised emissions from carbon stock changes caused by land use change; 
ep = emissions from processing; 
etd = emissions from transport and distribution; 
eu = emissions from the fuel in use; 
esca = emission savings from soil carbon accumulation via improved agricultural management; 
eccs = emission savings from carbon captu re and geological storage, and; 
eccr = emission savings from carbon capture and replacement. 
Emissions from the manufacture of machinery a nd equipment shall not be taken into account. 
Greenhouse gas emissions from the use of solid and gaseous biomass in electricity and/ or 
heating or cooling including the energy conv ersion to electricity and/ or heat or 
cooling produced shall be calculated as follows: 
For energy installations delivering only useful heat: 
elhEECη=
 
For energy installations deliv ering only electricity: 
helEECη=
 
For energy installations deliver ing only useful cooling: 
 
EN 84   EN ccEECη=
 
Where: 
EC hl = Total greenhouse gas emissions from the final energy commodity, that is 
heating. 
EC el = Total greenhouse gas emissions from the final energy commodity, that is 
electricity. 
EC c = Total greenhouse gas emissions from the final energy commodity, that is 
cooling 
ηel = The electrical efficiency, defined as the annual electricity produced divided by 
the annual fuel input. 
ηh = The thermal efficiency, defined as the annual useful heat ou tput, that is heat 
generated to satisfy an economically justifia ble demand for heat, divi ded by the annual fuel 
input. 
ηc = The thermal efficiency, defined as the annual useful cooling output, that 
cooling generated to satisfy an economically justifiable demand for cooling, divided by the 
annual fuel input. 
Economically justifiable demand shall mean the demand that does not exceed the needs of 
heat or cooling and which would otherwis e be satisfied at market conditions. 
For the electricity coming from energy installations deliver ing useful heat: 
⎟⎟
⎠⎞
⎜⎜
⎝⎛
⋅+⋅⋅=
h h el elel el
elelC CC EECηηη
η 
For the useful heat coming from ener gy installations delivering electricity: 
⎟⎟
⎠⎞
⎜⎜
⎝⎛
⋅+⋅⋅=
h h el elh h
hhC CC EECηηη
η 
Where: 
Cel = Fraction of exergy in the el ectricity, or any other ener gy carrier other than heat, 
set to 100 % (C el = 1). 
Ch = Carnot efficiency (fraction of  exergy in the useful heat).  
Carnot efficiency, C h, for useful heat at different temperatures: 
hh
hTTTC0−=
 
 
EN 85   EN Where: 
Th = Temperature, measured in absolute temp erature (kelvin) of the useful heat at 
point of delivery as final energy 
T0 = Temperature of surroundings, set at 273 kelvin (equal to 0 °C) 
For T h < 150 °C (423 kelvin), C h is defined as follows: 
Ch = Carnot efficiency in heat at 150 °C (423 kelvin),  which is: 0.3546 
V.5 Other issues  
Allocation for co-products upstrea m in the production pathway  
Co-products encountered in the production of elect ricity and heating are different than the co-
products in biofuels for transp ort, where an 'allocation method'  based on energy content was 
chosen. In the case of electric ity or heat producti on, the co-products do not always have 
energy content. Possible co-products include: digestates produced from biogas production 
(which can be used as ferti liser), ash, flue-gas (cleaning products) or surplus heat from 
combustion, char and gas as co-products of pyr olysis, compost as a sub-product of producing 
woodchips from gardening residues as well as nutriceuticals, fabr ic such as animal hides and 
pharmaceuticals, materials from the processi ng of sludge from waste water treatment 
(technosand) and cakes from oil processing.  
When considering policy tools, the arguments  for and against the different allocation 
approaches, as discussed in Annex 7, part F of the impact assessment for the renewables directive (based on exergy, energy, price an d substitution), still apply. The substitution 
method brings substantial uncertainties (Ecorys 2007
93), since it is difficult to know the 
marginal or the average process avoided. The economic allocation approach introduces 
uncertainties with regards to price changes, and methodological difficu lties regarding which 
prices to apply. Should one apply prices before tax;  because it is the market value, or after tax; 
since the tax supposedly represen ts external costs. Further; how to deal with prices of 
products that are subsidised upstream in the production chain?  Exergy allocation leads to 
methodological uncertainties, sinc e the definition and widespr ead use of "lower heating 
value" does not have a counter-p art within exergy, and many pr ocesses would be difficult to 
assess on an exergy basis. Exergy (2. law of  thermodynamics) is defined as the sum of 
"internal energy", "avail able PV work", "entropic loss" or "heat loss" and the final term 
"available chemical energy". To establish th ese terms for different pathways would be a 
methodological challenge. Energy allocation is t hus used. This conclusion also bears on the 
arguments presented in Annex 7, part F of the imp act assessment for the renewables directive.  
However, since a pure energy allocation would imply that positive side-effects of using e.g. 
landfill gas to energy purposes (the avoided methane emissi ons) would be neglected, the 
energy allocation rule is accompanied by a set of  appropriate default values, which gives the 
right incentives to utilise wastes, residues a nd by-products. This is discussed in the following 
section. 
                                                 
93 Ecofys (2007) "Towards a harmonised sustainable biomass certification scheme" 
 
EN 86   EN Land carbon stock figures  
Land use change can lead to emissions and these should be accounted or as accurately as 
possible. In the public consultation, a few stake holders explicitly commented on the need to 
develop carbon stock factors for short-rotation coppice and perennial grasses, as IPCC has not 
developed these. In the RES Directive it was deemed important to provide guidance on the 
emission factors to use when land use change o ccurs instead of providi ng single values in the 
legislation. This is because single value data ca nnot be used as instruments for regulation as 
production systems vary greatly depending on soils,  water balance, nutritional status, climate, 
etc, and cannot reflect the real impact of land use change for land use types spanning across 
different climatic zone/ growth zone or with di verse range of soils (org anic – inorganic soil). 
Respondents to the public consul tation also argued that car bon stock figures should take 
account of tropical and temperate climatic conditions. Guidance will be provided in the Communication on practical guidance for implemen ting the biofuels/ bioli quids sustainability 
scheme (due in the first quarter of 2010). In th is impact assessment, it is assumed that single 
values are not appropriate for the same reasons.
 
EN 87   EN ANNEX VI – Costs to economic operators asso ciated with efficiency  measures (ECORYS, 2009)  
Indicator  
BTC Type of 
measure Comments Compliance cost range  Unit 
compliance 
costs Efficiency 
increase 
possible 
(%) Total 
installed 
capacity Unit 
Installed 
capacity GWh 
(based on 
Green-X 
estimations of 
work done) Replacement 
rate Total 
gains/sav i
(GW )
    Low High  Lo
w High Low High   Low High Low H
Heat delivery Use of larger part of 
the heat 50,000,000200,000,00
0Euro per 
installation 33
% 65% 24 24 GW 
biomass  15% 60% 1 Large-scale 
power and 
CHP Add on Flue gas condenser 1,000,000 1,000,000 Euro/MW 8
% 10% 24 24 GW 
biomass  20% 60% <1 
Heat delivery Use heat, existing 
installations 50,000,000200,000,00
0Euro per 
installation 30
% 60% 1.1 1.1 Gwelectric 
-> only 
biomass 4988 5% 15% <1 
Co-firing  Heat delivery Use heat, new 
installations 50,000,000200,000,00
0Euro per 
installation 28
% 55% 4.8 9.5 Gwelectric 
-> only 
biomass 37335 20% 40% 1 
Heat delivery Use heat, existing 
installations 50,000,000200,000,00
0Euro per 
installation 35
% 70% 2.2 2.2 GW electric 
green 14008 10% 20% <1 
Heat delivery Use heat, new 
installations 50,000,000200,000,00
0Euro per 
installation 30
% 60% 1.6 1.6 GW electric 
green 9710 20% 40% <1 
Electrical 
efficiency 
improvement Improvements, 
existing installations 10,000 12,000 Euro/kW 1
% 2% 2.2 2.2 GW electric 
green 14008 20% 50% <1 
Waste 
incineratio
n Electrical 
efficiency 
improvement Improvements, new 
installations 6,000 10,000 Euro/kW 6
% 10% 1.6 1.6 GW electric 
green 9710 60% 90% <1 
District 
heating Add on Flue gas condenser 1,000,000 1,000,000 Euro/MW 8
% 10% 12 12 GW thermal 42210 20% 60% <1 
External heat 
delivery Use heat 2,000,000 10,000,000Euro per 
installation 20
% 35% 2.0 1.9 GW thermal 10,771  10% 50% <1 
Manure 
(co-) 
digestion Add on ORC on an average 
700 kW digester 400,000 0Euro per 
installation 8
% 15% 1.7 1.9 GW electric 10,771 50% 90% <1 
 
EN 88   EN  
ANNEX VII – Typical and default emission  values for solid and gaseous biomass pathways (calculated using JRC data, 2009)  
JRC calculated the emissions of various pathways using the following assumptions: 
– For EU forestry residues, transportation is  assumed to be by truck 50 km, 100km in ca se of intermediate processing (e.g. brique tting, 
pelletising, chipping) 
– For raw materials coming from tropical countri es (Brazil, Indonesia, Thai land), transportation to the processing site is assume d to be by 
truck, 50 km, and transport to the export te rminal, 700km, while transport to the EU vary for Brazil (by ship, 10186 km, and fo r 
Indonesia by ship, 13000 km and for Thailand by ship 12500 km). 
 
EN 89   EN  
 Typical  Default 
Biofuel production pathway GHG emitted (g CO2eq/MJ) GHG emitted (g CO2eq/MJ) 
         
 Cultivation Processi
ng Transport & 
distribution Total Cultivation Processing Transport & 
distribution 
Wood chips from forest resi dues (EU forest) 0.0 0.4 0.3 1 0.0 0.4 0.4 
Wood chips from forest residues (Brazilian forest) 0.0 0.4 20.0 21 0.0 0.4 23.9 
Wood chips from short rotation fo restry (EU forest) 2.0 0.4 0.3 3 2.5 0.4 0.4 
Wood chips short rotation forestry (eucalyptus) 2.9 0.4 20.0 24 3.5 0.4 23.9 
Wood briquettes or pellets from forest residues (EU forest) – wood 
as process fuel 0.0 0.5 0.7 2 0.0 0.5 0.8 
Wood briquettes or pellets from forest residues (EU forest) – NG as 
process fuel 0.0 15.4 0.9 17 0.0 18.4 1.1 
Wood briquettes or pellets from forest residues (Brazilian forest) -
wood as process fuel 0.0 0.5 13.7 15 0.0 0.5 16.4 
Wood briquettes or pellets from forest residues (Brazilian forest) - 
NG as process fuel 0.0 15.4 13.7 30 0.0 18.4 16.4 
Wood briquettes or pellets from short rotation forestry (EU) - wood 
as process fuel 2.1 0.5 0.7 4 2.5 0.5 0.8 
Wood briquettes or pellets from short rotation forestry (EU) - NG as 
process fuel 2.1 15.4 0.6 19 2.5 18.4 0.7 
Wood briquettes or pellets from short rotation forestry (eucalyptus) - 
wood as process fuel 3.6 0.5 13.7 18 4.4 0.5 16.4 
Wood briquettes or pellets from short rotation forestry (eucalyptus) - 
NG as process fuel 3.6 15.4 13.7 33 4.4 18.4 16.4 
        
Charcoal from forest residues (EU) 0.0 32.8 0.7 34 0.0 39.4 0.8 
Charcoal from residues (Brazilian forest) 0.0 32.9 8.0 41 0.0 39.5 9.6 
Charcoal from short rotation forestry (EU)  4.1 32.9 0.7 38 5.0 39.5 0.8 
Charcoal from short rotation forestry (Eucalyptus) 5.9 33.0 8.0 47 7.0 39.6 9.6 
        
wheat straw (EU) 0.0 0.8 0.3 2 0.0 1.0 0.3 
Bagasse briquettes – (Brazil) wood as process fuel 0.0 0.0 13.5 14 0.0 0.0 16.2 
Bagasse briquettes – (Brazil) NG as process fuel 0.0 15.0 13.5 29 0.0 18.0 16.2 
Bagasse bales (Brazil) 0.0 0.8 15.8 17 0.0 1.0 18.9 
Palm kernel (Indonesia) 0.0 0.0 21.8 22 0.0 0.0 26.2 
        
Rice husk briquettes (Thailand) 0.0 0.0 23.3 24 0.0 0.0 28.0 
Mischanthus bales (temperate continental climate) 3.6 1.1 0.3 6 4.4 1.4 0.3 
biogas from wet manure  0.0 5.0 1.6 7 0.0 6.0 1.9 
biogas from dry manure  0.0 5.0 0.5 6 0.0 6.0 0.6 
         
Biogas from wheat and straw (wheat whole plant) 16.9 0.0 0.3 18 20.3 0.0 0.3 
Biogas from maize as whole plant (maize as main crop) 14.3 5.0 0.0 19.3 17.2 6.0 0.0 
Biogas from maize as whole plant (maize as main crop) – organic 
agriculture 10.7 5.0 0.0 16 12.8 6.0 0.0 
 
EN 90   EN