EN    EN EN 
 
EN    EN  EUROPEAN COMMISSION 
Brussels, 25.2.2010 
SEC(2010) 66 final 
  
COMMISSION STAFF WORKING DOCUMENT 
SUMMARY OF THE 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) 65 final 
 
EN 2   EN 1. PROBLEM DEFINITION  
The EU needs to increase its use of biomass for energy purposes to reach the 2020 targets 
agreed under the Renewable Energy Directive1. The Directive contains a sustainability 
scheme for biofuels and bioli quids. Article 17(9) of the Dir ective 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.  
Solid and gaseous biomass can originate from agriculture, forestry or waste. As biomass 
resources are not infinite, an efficient and su stainable use of the resource is important. 
Market failures may occur because climate change and potential negative impacts on 
biodiversity, water, soils and ecosystem serv ices are not reflected in market prices.  
Regulatory failures may occur because renewable energy policy encourages Member States to 
support the use of more biomass, while rules or pricing mechanisms for biomass production 
do not take into account negative extern alities, such as deforestation.  
These failures are not observed today on a significan t scale, and in particularly not in the EU. 
However, it may be appropriate  to create safeguards against their arising in future, where 
more biomass and an increased amount of impor ted biomass are expected to be used for 
energy purposes.
 
2. ANALYSIS OF SUBSIDIARITY  
Biomass can be easily traded. It follows that if  Member States act alone, the internal market 
may be disrupted for biomass traders, supplie rs and producers. EU-wide action can ensure 
that common environmental protection is achieve d while avoiding distorti ons in the internal 
market.  
3. OBJECTIVES OF EU INITIATIVE  
The general policy objective is to guarantee a sustainable use of biomass for energy purposes. 
The specific objectives are to ensure that he at and power uses of biomass leads to (1) 
sustainable production, (2) high greenhouse (GHG) performance co mpared to fossil fuels and 
(3) efficient energy conversion of biomass into electricity and heating and cooling. 
The operational objective is to establish sustai nability 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. 
                                                 
1 Directive 2009/28/EC 
 
EN 3   EN 4. POLICY OPTIONS  
Table 1: Summary table of options 
A. Production of biomass Policy Scenario 
 
Option A1: no new EU action Voluntary schemes continue to elaborate certification schemes for 
sustainable biomass production and land management.  
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 and 
leaves. 
Option A3: minimum criteria on 
biodiversity and land use  Criteria on biodiversity and land us e or so-called 'no-go' areas under 
the Renewable Energy Directive to apply to all biomass. Forest 
management issues are left out of the scope.  
Option A4a: Option A3 + reporting 
on biomass origin As Option A3 + reporting requiremen ts on Member States on biomass 
origin. 
Option A4b: Option A3 + reporting 
on Sustainable Forest Management 
(SFM) As Option A3 + mandatory reporting requirements on Member States 
on sustainable forest management.  
Option A5: Option A3 + SFM 
minimum obligations As Option A3 + obligations on Member States to count forest 
biomass only from sustainable managed forests towards their 
renewable energy target. 
Option A6: Option A3 + LULUCF 
accounting As Option A3 + evidence of good practice in case country of origin 
does not account LULUCF emissions. 
B. GHG savings:  
Option B1: no new EU action GHG performance requirements could be developed in voluntary 
schemes. 
Option B2: labelling of GHG 
performance Label GHG performance to give info rmation to electricity or heat 
consumers and to promote GHG life cycle thinking for production 
processes. A common GHG methodology for labelling would be 
necessary to ensure consistency of claims. The obligation could be 
placed on electricity and heat pr oviders, and the GHG performance 
could be made available on guarantees of origin, for disclosure 
purposes. 
Option B3: Setting minimum GHG 
savings requirements - 35% 
(increasing to 50-60% in 2017/2018)  35% minimum GHG saving requirement for agricultural and forest 
biomass (compared to fossil alternative) - same minimum requirement 
as for biofuels and bioliquids in the Renewable Energy Directive 
Option B4: minimum GHG 
requirements in accordance with 
GHG saving potential  Introduce minimum GHG requirement in accordance with the Best 
Available Technology (BAT) in each pathway. 
C. Conversion  
Option C1: No new EU action Existing energy efficiency policy will yield results in making the use 
of all energy resources, includi ng biomass, more efficient.  
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.  
 
EN 4   EN Option C3: banning inefficient use 
or minimum effici ency standards Banning certain inefficient biomass technology options or introducing 
minimum requirements. Small-scale (m ainly residential) use is out of 
the scope as dealt with by other EU policy.  
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 e.g. through labelling energy savings on the 
guarantee of origin. 
Option C5: improve supply chain 
efficiency A GHG life cycle methodology to incl ude end-conversion efficiency.  
Options A2, A4b, A6, C4 and C5 were discarded as it was considered that the policy tools 
were not effective to address the problems identified. 
5. ASSESSMENT OF IMPACTS  
5.1. Environmental impacts 
No policy tool can give certainty that forests will be regenerated after biomass is harvested. 
Options A3 and A4a ensure that highly biodiverse areas, such as primary forests, cannot be 
converted for the production of biomass and that  high carbon stock areas such as forests must 
remain high carbon stocks areas even after biomass production. Option A5 would require 
evidence of managing the forest sustainably, ho wever such evidence is difficult to verify 
without globally agreed common requireme nts on sustainable forest management.  
When considering the GHG benefits  of the different options, it is  evident that for most solid 
biomass chains used in electricity and heati ng, the savings are significant compared to using 
fossil alternatives (see Graph 1) 2.  
                                                 
2 Land use emissions are assumed to be zero. Losses for energy conversion are included, based on 
assumptions of 25% electrical co nversion efficiency, and 85% th ermal conversion efficiency. 
 
EN 5   EN Graph 1: GHG savings potential of solid biom ass feedstocks 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 coppicing, FR to forest residues and NG to natural gas 
Given the high greenhouse gas performance of th e main feedstocks, labelling these emissions 
(Option B2) is not likely to lead to additiona l GHG savings. Option B3 will lead to between 
5-20% additional GHG savings an d ensure that requirements are set in line with the 
Renewable Energy Directive to provide consiste ncy for those feedstocks  that can be used 
either for transport purposes or for electricity and heating. Option B4 will lead to some additional GHG savings by leading to improvements in the ch ain, such as using wood instead 
of natural gas for the processing fuel. In the ca se of pelletising, switching from natural gas to 
wood as process fuel, would lead to an  improvement of around 35% GHG savings in 
electricity production.  
When considering the conversion efficiency options, positive environmental impacts are 
dependent on the effectiveness of policy options to replace fossil fuel alternatives. The biggest 
improvements in efficiency could come from utilising the heat in electricity only plants (i.e. switching to combined heat and power). Settin g minimum efficiency standards (Option C3) 
only for biomass and not for fossil fuels may lead  to negative environm ental impacts, as the 
use of biomass may be disincen tivised by higher costs. Providi ng a bonus or a penalty (Option 
C2) in support schemes would avoid the switching away from biomass to fossil, as a bonus usually means an additional incen tive on top of other incentives to use renewable energy (e.g. 
more green certificates, price pr emium on top of feed in tari ffs, investment subsidy etc). 
5.2. Economic impacts 
5.21. Costs to public administration The cost for public administrations to verify th e origin of biomass (c hain of custody) under 
Options A3, A4a, A5, was estimated by using the EU's Standard Cost Model. Total costs for 
the EU-27 were estimated. One-off costs were estimated to be €0.3-1.1 million and recurring 
 
EN 6   EN costs between €0.1-0.2 million per year. Recurri ng costs include the cost of the annual 
reporting requirements under Option A4a to the Commission. Additional costs will be 
incurred for verifying the household use of biomass through surveys. Under Option A5, 
additional costs may be incurred depending on requirements for sustainable forest 
management.  
The cost for Options B3 and B4 are in the same range as costs under Options A3, A4a and A5 
as the highest costs are associated with putting the legislation in place. A single threshold for 
GHG savings under Option B3 may decrease the administrative burden. Developing default 
values for pathways using different processes (e.g. wood or natural gas used as process fuel) 
would allow the use of a single threshold, while reflecting the differences in emissions in the 
different processes (as under Option B4). 
As regards the options to increase energy convers ion efficiency, the costs to public authorities 
are lower where the policy is easily combin ed with existing measur es (e.g. bonus on top of 
existing support scheme), but higher where mini mum standards are set for technologies that 
are diverse and dispersed (e.g. district heating) . Administrative costs we re calculated using the 
EU standard cost model: for option C2 costs range between €400,000-1.6 million and for 
Option C3 between €700,000-3.7 million. 
5.2.2. Cost to economic operators 
To estimate the cost of providing proof of the origin of biomass, the EU's Standard Cost 
Model was used. Recurring chain of custody (C oC) certification costs under Options A3 and 
A4 were estimated to be between €800-3,000 per year for individual biomass producers. The potential costs of implementing minimum sustai nable forest requirem ents (Option A5) are 
higher, between €2,000-24,000 per year.   
Under Option B2, B3 and B4, it was found that the cost of GHG certification is 10-20% 
higher when the operators have to show actua l GHG savings of the bio-energy chain. Costs 
calculated for the EU-27 showed that for pr ocessors, manufactures , traders and energy 
producers, the recurring costs are 60-70% hi gher when GHG certification is imposed 
compared to CoC certification alone. For indi vidual energy producers above 1 MW capacity 
the recurring costs can vary  between €898-5,643 per year.  
The cost of increasing efficiencies through usi ng the produced heat, usin g add-ons to increase 
electricity or heat producti on, increasing the plants size or  technology improvement costs 
were assessed. An option for minimum effici ency requirements (Option C3), which would 
require the use of heat, could lead to cons iderable compliance costs, between €50-200 million 
per installation. It is difficult to say what co st a bonus in a support scheme (Option C2) would 
have on operators, if any, as suppo rt is a voluntary measure, where a company is free to make 
use of the bonus.  
5.2.3. Economic availability of biomass 
In developing its renewable energy policy, the Commission had based its assumptions on 
biomass availability on a study carried out by the European Environment Agency (EEA)
3, 
                                                 
3 EEA (2007): Environmentally compatible bio-ener gy potential from European forests. Copenhagen, 
European Environment Agency 
 
EN 7   EN which estimated that around 235 Mtoe biomass will be available in 2020 for energy use, 
without harming the environment.  
An updated assessment of wider literature finds that there are large di fferences in estimates 
for biomass potentials. These differences are largely due to assumptions made about the 
availability of land, which is heavily influenced by productiv ity development assumptions.  
The availability studies however did not so far l ook at the impact of sust ainability criteria on 
costs. The impact assessment found that the unde rlying studies usually limit their analysis to 
currently available agricultural lands and exclude  highly biodiverse or nature protected areas4. 
It is therefore expected that the lion’s sh are of the biomass potential will meet the land 
exclusion criteria and not have any impact on their economic availability. 
Options B1 and B2 do not impose minimum criter ia and therefore would not have any impact 
on the economic availability of biomass. Op tion B3 would set a 50-60% minimum threshold 
for all existing/ new electricity and heat pl ants from 2017/2018 respectively. It was found that 
many biomass chains that do not meet the 50-60% thresholds by their 2008 typical values 
(derived from Annex V of the Renewable En ergy Directive) are projected to do so by 2020 
through technological or efficiency improveme nts. The additional costs for carrying out 
improvements in these chains to reach the GHG savings require ments are estimated to be 
around €38-€62 million for the year 2020. 
In terms of the options for increased conversi on efficiency, any impact is likely to be a 
positive one, as a product of using less biomass to replace more fossil.  
5.3. Social impacts 
5.3.1. Households  Sustainability criteria for biom ass would not lead to  significant impact s on households, as 
GHG savings obligations is not likely to be  put on households due to the difficulty in 
monitoring small-scale users.  
5.3.2. Employment 
Employment effects are considered negligible. Some employment impacts can arise from 
sustainability criteria wher e criteria lead to investment effect s, i.e. increase in the demand in 
biomass related services and biom ass-technology producing sectors.  
6.
 COMPARISON OF OPTIONS  
The assessment shows that on the production side, the policy option for putting in place 
minimum requirements for avoidance of bioma ss production from highly biodiverse lands and 
avoidance of negative land use change (i.e. same criteria as in the Renewable Energy 
Directive) is the most cost-efficient. Sett ing minimum thresholds or obligations for 
sustainable forest management could lead to high costs for industry.  
                                                 
4 Dornburg et al (2008): Assessment of global bi omass potentials and their links to good, water, 
biodiversity, energy demand and economy. Bilthoven, MNP. 
 
EN 8   EN As regards greenhouse gas performance, consiste ncy with the Renewable Energy Directive is 
important. An EU-wide harmonised GHG methodol ogy to calculate life cycle emissions is 
recommended. To avoid distortions in the market, the policy option setting minimum GHG 
savings requirement at 35% and increasing to 50% from 2017 for existing plants and 60% for 
new plants from 2018 is recommended as it is  consistent with the Renewable Energy 
Directive. Wastes and processing residues, wh ich routinely achieve hi gh GHG savings should 
not need to fulfil such requirements. 
On improving energy conversion efficiency, most of the policy options would only be 
effective if fossil alternatives were also c overed by them. It is not recommended to set 
efficiency standards only for biomass pathwa ys, because that may encourage more fossil 
energy being used instead. Option C2 is the pr eferred option, where Member States would be 
responsible for incentivising high efficiency conversion in their support schemes for large 
(above 1MW) electricity a nd heat installations.  
When considering the question of whether or not these policy options shoul d be in the form of 
binding criteria or recommendations to Member States, it was taken into  account that biomass 
will come from both the EU and imported from  outside the EU. Currently the import of 
biomass from outside the EU is around 3%.  
Binding criteria would have the effect that onl y biomass considered su stainable under an EU-
wide scheme would count towards the renewabl e energy target. A voluntary approach based 
on recommendations from the Commission would not  allow Member States to refuse to count 
biomass which does not fulfil the obligations of  the national scheme towards the renewable 
energy targets. Member States could however d ecide not to give financial support for biomass 
not meeting the national criteria.  
7. MONITORING AND EVALUATION  
The core indicator for meeting the objectives is the increasing use of biomass without leading 
to deforestation and other negative environmen tal impacts. Reporting and monitoring systems 
are available through Eurostat at EU level, but  will need to be strengthened, including at 
national level, for more accurate results.