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
Date: 2010-02-25
Institutions: European Commission
Subjects: bioenergy, electrical energy, energy efficiency, greenhouse gas, heating, impact study, management of resources, physical process, reduction of gas emissions, renewable energy, sustainable development

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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 

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Lead DG: TREN 

Other  involved  services:  ENV,  ENTR,  AGRI,  ECFIN,  COMP,  TAXUD,  DEV,  RTD,  SG, 
JRC, TRADE, RELEX 

Agenda planning or WP reference: TREN WP 2009 Item 37 

Section 1: Procedural issues and consultation 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 established. The first meeting took place on 9th 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 March 2009 to debate the policy options and to 
update  the  services  about  the  external  studies  and  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  28th  September  2009,  recommending 
clarification of the distinction 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 final version of the Impact Assessment.  

•  Consultation and expertise  

A  public  consultation  was  carried  out  July-September  2008.  252  responses  in  total  were 
received, of these, 243 have been taken into account, due to some replies being sent more than 
once  and/or  from  the  same  business  association  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 

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– 

– 

– 

– 

Consideration  of  the  greenhouse  gas  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  citizens  and  the  rest  came  from 
organisations,  among  which  58%  were  industry  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 sustainability requirements for biomass are necessary.  

Many stakeholders called for consistency with the sustainability scheme for biofuels used for 
transport as laid down in the RES Directive, and claimed that the 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  down  in  the  RES  Directive.  18%  advocated  a 
legally  binding  scheme  where  biomass  producers  (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 electricity and heat producers (excluding households) 
to procure only sustainable biomass. Those who 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 sustainable forestry are sufficient. Most proponents of 
a voluntary scheme came from forest-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  justifiable  without  also 
having legally binding schemes for 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  saving  of  35%,  (i.e.  the  same 
threshold as for biofuels and bioliquids as the Commission proposed in the RES Directive2). 
18% of the respondents (including some public authorities and environmental organisations) 
advocated a threshold figure which should be higher than for biofuels for transport, whereas 
5%  argued  for  a  threshold  figure  lower  than  for  biofuels  (e.g.  waste  industry).  19%  of  the 
respondents  objected  to  setting  requirements  for  GHG  savings  for  biomass  in  general 
(including forest-based industry).  

On  the  question  of  promoting  efficient  energy  conversion,  there  was  wide  support  among 
respondents for using resources efficiently but some argued that energy-conversion efficiency 
should  be  treated  separately  because  efficiency  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. 

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On  sustainable  production  of  biomass,  67%  of  respondents  were  in  favour  of  sustainable 
forest  management  criteria  for  forest  biomass,  but  the  33%  of  respondents  who  opposed 
sustainable  forest  management  criteria  considered  that  proper  implementation  of  existing 
criteria  defined  by  the  Ministerial  Conference  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  international  organisations,  said  that  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  specific  guidance  and  regulation  of  biomass  for 
energy purposes should be simple and should allow simple methods of production by small-
scale producers. 

The results of the public consultation can be found at: 

http://ec.europa.eu/energy/renewables/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: evaluation of options to promote biomass 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/SI2.528333  on  "Technical  assistance  for  an 
overview of international trade opportunities for sustainable biomass and biofuels", carried out 
by  the  COWI  Consortium  consisting  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  Certifications.  The  contract  started  in  April  2009 
and final report  on  tasks  1  and  2  (global availability 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  forest  management  was  submitted  at  the  end  of 
October 2009 (The COWI Consortium 2009).  

3.  A  study  by  the  Biomass  Technology  Group  BTG  BV3  on  "Sustainability  Criteria  and 
certification systems on sustainable biomass production" was finalised in February 2008 and 
served  as  an  input  into  the  assessment  (BTG,  2008).  The  study  is  available  at: 
http://ec.europa.eu/energy/renewables/bioenergy/doc/sustainability_criteria_and_certification
_systems.pdf.  

The  Commission  organised  and  attended  various  conferences  and  stakeholder  meetings, 
including: MCPFE ad-hoc working group on biomass 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 pathways for biomass held on 7 April 2009. 

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BTG (2008) "Sustainability criteria and certification systems on sustainable biomass production", The 
Netherlands 

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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 efficient 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  and  bioliquids  are  covered  by  a  sustainability 
scheme  under  Articles  17-19  of  the  RES-Directive.  BOX  A  below  explains  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  (including  vegetal  and  animal  substances),  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  biomass  is  either  transformed  into  transport  biofuels,  bioheat  or 
bioelectricity. 

Biomass originates from forest (logs, bark, wood chips, sawdust, pellets etc) agriculture (rape, 
wheat, maize etc) and waste streams (municipal 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 technologies for bio-energy production. 
These conversion routes use chemical, thermal and/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 

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The first issue to consider is biomass availability. There is a variety of literature on the future 
availability of biomass for energy purposes. In its proposal for a Renewable Energy Directive, 
the Commission based its assumptions on biomass 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  biomass  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  lower  productivity  growth  estimations  due  to 
environmentally sound farming (e.g. organic farming) for 2020 and does 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 projected to decrease, the consumption of food is saturated, while the 
efficiency  of  agriculture  is  projected  to  increase.  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  are  reasonable  given  the 
literature  sources,  but  that  the  Green-X  model  may  be  optimistic  on  the  availability  and 

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EEA  (2007):  Environmentally  compatible  bio-energy  potential  from  European  forests.  Copenhagen, 
European Environment Agency 
As 
presented 
http://ec.europa.eu/energy/renewables/studies/doc/renewables/2009_employ_res_report.pdf 

EMPLOY-RES 

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(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 availability is presumed to meet the EU's 2020 targets 
domestically, there is a risk of negative environmental impacts, linked to the increased use of 
the resource and increased imports.  

Biomass  is  an  easily  tradable  good  and  environmental  protection  or  sustainable  energy 
policies  are  not  uniform  across  the  EU  or  indeed  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 management, 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, water, soils and ecosystem services.  

- regulatory failure: renewable energy policy encourages Member States to use more biomass 
to meet their targets, while rules or pricing mechanisms for biomass production do not always 
take into account negative externalities, 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  recent  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  particular,  there  is  a  lack  of 
coherent sustainability rules and regulations with regard to biomass (FAO, 20097).One of the 
root causes behind deforestation in the developing world is the weak governance structure for 
forest conservation and sustainable management of forest resources.  

At a global level, the United Nations Framework Convention on Climate Change (UNFCCC)8 
is  currently  discussing  a  new  agreement  including  on  how  to  account  for  emissions  and 
removals  from  forests  as  well  as  how  to  reduce  emissions  from  deforestation  in  developing 
countries. Should these processes fail to correct the market failures, there would be concerns, 
in  particular  for  imported  biomass,  that  increased  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 natural biodiversity.  

In Europe, environmental risks are more to do with new practices arising from the intensified 
use of forests. This includes practices such as stump extraction and the 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 the EU. Initial research suggests 
that  if  stumps  are  harvested  in  vulnerable  areas,  it  may  lead  to  soil  damage,  carbon  loss, 
erosion and increased turbidity and siltation of local watercourses. The removal of essential 
nutrients  (e.g.  nitrogen,  phosphorus,  potassium  and  boron),  could  also  lead  to  lower  soil 
fertility, and potential loss of tree growth in subsequent rotations. Removal of base cations9 

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FAO (2009) "Small-scale bioenergy intiatives", ftp://ftp.fao.org/docrep/fao/011/aj991e/aj991e.pdf  
http://unfccc.int/2860.php  
Base cations are the most prevalent, exchangeable and weak acid cations in the soil, including ions such 
as calcium (Ca2+), magnesium (Mg2+) potassium (K+) and sodium (Na+) 

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(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 during harvesting and supply of stumps 
as well as utilisation of wood ash as a compensatory fertiliser corresponds to 5.6 % of carbon 
content in biomass, according to the Forest Research Institutes of Latvia and Sweden11. 

Similar  uncertainties  exist  about  removing  branches  and  leaves  (i.e.  other  forest  residues), 
which  are  important  sources  of  forest  nutrients,  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  quality  and  reducing  yields.  These 
forest  management  practices  can  lead  to  overall  carbon  stock  changes.  Regulatory  failures 
come from the lack of information on these practices.  

In agriculture, there is a risk that intensive fertilisation 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  agricultural  residues  like  straw  for  heating  may 
deteriorate  soil  organic  matter  (and  therefore  carbon  balance)  and  soil  fertility,  lead  to 
intensified  use  of  grasslands  and  more  frequent  cutting  of  hedges  which  may  endanger 
biodiversity.  Management  practices  (intercropping,  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  interest  for  short-term  profits  can 
outweigh the importance of long-term productivity. However, in the EU, agriculture is subject 
to  a  set  of  environmental  rules  under  the  Common  Agriculture  Policy  and  under  common 
environmental rules. 

2)  GHG  performance  throughout  the  whole  chain  (production  (cultivation/harvesting)  – 
transport - processing – transformation):  

–  regulatory  failure  if  biomass  used  for  energy  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 transport, because the processing steps (e.g. pelletisation) 
generally  consume  less  energy  than  the  processes  required  to  make  transport  biofuels.  It 
should be noted however, that while biogas from waste generally has a very favourable GHG 
profile,  biogas  production  from  agricultural  crops  can  lead  to  more  emissions  due  to 
emissions associated with the production phase.  

3)  Inefficient  conversion  of  resource  to  useful  energy  -  a  lack  of  clear  and/or  common 
standards/ rules for using biomass feedstocks efficiently leads to processes which may lead to 
an overuse of resources.  

– 

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regulatory  failure  because  sometimes  the  inefficient  use  of  biomass  is  given  state 
support 

http://www.forestry.gov.uk/fr/INFD-7RBJ23  
Andis et al (May 2009) "Productivity and cost of stump harvesting for bioenergy production in Latvian 
conditions",  http://tf.llu.lv/conference/proceedings2009/Papers/33_Andis_Lazdins.pdf,  LSFRI  and 
SKOGFORS 
UN-Energy 
http://www.fao.org/docrep/010/a1094e/a1094e00.htm  

decision  makers" 

"Sustainable 

framework 

energy: 

(2007) 

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– 

market  failure  also  exists  as  imperfect  information  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-energy (open stoves for heating and cooking) can 
affect the health of people, causing respiratory diseases. However, the impact assessment will 
not  deal  with  these  risks  because  local  emissions  are  also  regulated  by  other  European 
legislation, such as Directive 2008/50/EC which sets standards and target dates for reducing 
concentrations of fine particles, which together with coarser particles known as PM10 already 
subject  to  legislation,  are  among  the  more  dangerous  pollutants  for  human  health.  Local 
emissions  from  small-scale  plants  are  regulated  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  emissions  limits  for  carbon  monoxide  (CO), 
unburned hydrocarbons or organically bound carbon (OGC)13 and for particles. Labels have 
been developed in some Member States to certify 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  waste  (including  municipal 
solid  waste,  biowaste,  sewage  sludge)  for  energy  rather  than  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 given 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 risk of insect infection, economic benefits like 
diversification  of  income  possibilities  for  farmers  and  forest  owners  and  rural  areas  as  a 
whole. Positive impacts could arise from perennial grasses or short rotation coppicing grown 
on agricultural land, by increasing the soil carbon content as compared to annual agricultural 
crops (UN-Energy, 200712). 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  change  of  increasing  the 

13 

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15 

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 NOx. (Eskilsson et al, 2002) 
2001/80/EC or the Large Combustion Plants Directive aims toreduce emissions of acidifying pollutants, 
particles,  and  ozone  precursors  from  large  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 total emissions in 2010 of 
the  four  pollutants  responsible  for  acidification,  eutrophication  and  ground-level  ozone  pollution 
(sulphur dioxide, nitrogen oxides, volatile organic 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 including emission limit  values based on Best Available 
Techniques  (BAT),  also  for  biomass  plants  above  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. 
For  the  purpose  of  this  impact  assessment,  waste  from  agriculture  and  forestry  will  be  referred  to  as 
processed agricultural and forest residues 

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consumption of biofuels and bioliquids by 2010. The results of that work will give indications 
on  whether  or  not  the  indirect  land  use  change  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 decreasing globally (in particular 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 people who depend on the forest for income or 
for  living.  Some  developing  countries  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 generation, diversification of 
enterprises and rural economies.  

If biomass is used inefficiently, it may not contribute 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  assessment  looks  at  the  impacts  of  introducing 
sustainability criteria. The baseline scenario developed below does however take account of 
the  projected  increases  in  the  use  of  biomass,  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-RES17 study, ‘advanced deployment policy’ 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 tonnes of oil equivalent (Mtoe) biomass will 
be used for energy purposes in the EU in 2020 (the realisable potential is projected by Green-

16 

17 

18 

19 

20 

21 

Umweltbundesamt,  Ökoinstitut,  IFEU  (2009).  Sustainable  Bioenergy:  Current  Status  and  Outlook; 
March 2009 
Ragwitz M, Schade W, Breitschop B, Walz L., Helfrich N, Rathmann, M, Resch G., Panzer C, Faber 
T.,., Held A., Haas R, Nathani C, Holzhey M, Konstantinavicitute 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/studies/doc/renewables/2009_employ_res_report.pdf  
The  European  Energy 
/2007/  Efficiency 
http://ec.europa.eu/dgs/energy_transport/figures/trends_2030/index_en.htm  
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 
Ragwitz M, Held A, Resch G., Faber T, Haas R, Huber C, Coenraads R, Voogt M, Reece G, Morthorst 
P,  Jensen-Risoe  S,  Konstantinavicitute  I  (2007)  "Assessment  and  Optimisation  of  renewable  energy 
support schemes in the European electricity market", Karlsruhe, Germany 
Coenraads R, Reece G, Voogt M, Ragwitz 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 

and  Transport  Trends  by  2030 

case 

- 

EN 

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X  to  be  221.6  Mtoe  in  2020,  excluding  imports)  in  primary  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 ‘technological learning’ and due to existing policies 
on energy efficiency22. Energy efficiency of renewable energy 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  increases  the  renewable  energy  share  counting 
towards the target. This especially incentivises biomass heating, where losses are low. Annex 
II shows the baseline efficiencies assumed for specific bio-energy technology combinations.  

The baseline scenario for land use is more difficult to determine. Europe has seen increased 
afforestation,  while  globally  gross  deforestation  is  estimated  at  13  million  hectares  a  year 
(UNEP,  200823).  It  is  difficult  to  quantify  what  proportion  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 significant (around 3 Mtoe mainly from Canada and Russia), but in the baseline 
it is assumed that imports could more than double in 202025. 

Measures  to  address  the  issue  of  deforestation  and  encourage  afforestation  are  being 
developed.  In  Europe,  the  Ministerial  Conference  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  deforestation  and  forest  degradation  in  developing 
countries (REDD30) are ongoing.  

International  processes  have  also  acknowledged  the  importance  of  forest  protection  and 
sustainable  forest  management  and  increasingly,  voluntary  sustainability  schemes  are 
provided by companies, independent  organisations or through national or  intergovernmental 
structures  (see  Annex  III  for  an  analysis  of  developments  in  the  different  sectors).  The 

22 

23 

24 

25 
26 
27 
28 
29 
30 

These  include  the  Eco-Design  Directive,  the  Energy  Star  Regulation,  the  Labelling  Directive,  the 
Energy  Performance  of  Buildings  Directive,  the  Cogeneration  Directive  and  the  Directive  on  Energy 
End-Conversion  Efficiency  and  Energy  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  energy  efficiency  target  (through 
implementing  energy  efficiency  legislation),  Member  States  have  put  in  place  energy  efficiency 
obligation  and  White  Certificates,  end-conversion  efficiency  requirements  for  biomass  in  support 
schemes, household subsidy schemes for efficient pellet boilers and investment grants for small CHP. 
UNEP,  FAO,  UNFF  (2008)  "Vital  forest  graphics:  stopping  the  downswing?",  UNEP/  Grid-Arendal, 
2008, http://www.grida.no/publications/vg/forest/  
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 
Green-X projections 
http://www.mcpfe.org/documents/r_2007/  
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2005:0084:FIN:EN:DOC  
http://ec.europa.eu/agriculture/fore/action_plan/index_en.htm  
COM(2003)251 final and COUNCIL REGULATION (EC) No 2173/2005 
COM(2008)648/3 "Addressing the challenges of deforestation and forest degradation to tackle climate 
change and biodiversity loss" 

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11 

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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  loss.  Voluntary  and  inter-governmental  initiatives  to  fight 
deforestation and proposed requirements by the European Commission on economic operators 
to exercise due diligence to avoid illegal logging33, 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 International  Panel on Climate Change (IPCC) estimates 
that the amount of carbon absorbed in the soil and vegetation amounts to approximately 1.1 
Gt/year.  Due  to  inter-annual  variability  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  deforestation  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 – were running at 1.6 Gt of carbon per year in the 1990s (central 
estimate),  or  around  20%  of  the  world’s  total  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  this  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-
RES37). 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 biofuels and biomass production. From additional 
biomass provision alone (fuel use effects), around 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  look  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 moderate energy cost increases resulting from 
renewable energy policies. On local communities dependent on forests, a baseline scenario is 

31 
32 
33 
34 
35 
36 

37 

UNFCCC - United Nations Framework Convention on Climate Change Art 4 1. (d) – www.unfccc.int 
https://www.cbd.int/forest/portal/home.shtml 
COM(2008) 644 
ESD : Decision No 406/2009/EC of the European Parliament and of the Council of 23 April 2009 
Directive 2009/29/EC of the European Parliament and of the Council of 23 April2009 
UNFCCC  OECD  countries  are  required  to  make  available  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. 
http://ec.europa.eu/energy/renewables/studies/doc/renewables/2009_employ_res_report.pdf 

EN 

12 

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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 that there will be a complex set of sustainability 
requirements  developing  at  national  or  regional  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 prove several criteria depending on the end market and therefore 
creating market distortions between different sources of biomass. For this reason the legislator 
in the RES Directive specified that "if the analysis done […] demonstrates that it would be 
appropriate  to  introduce  amendments,  in  relation  to  forest  biomass,  in  the  calculation 
methodology in Annex V or in the sustainability criteria relating to carbon stocks applied to 
biofuels  and  bioliquids,  the  Commission  shall,  where  appropriate,  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 added value of the Community therefore is that the same rules 
would  apply  throughout  the  Community.  There  are  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 consistency of these objectives with other EU policies 

The general policy objective is to guarantee a sustainable 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 GHG performance compared to fossil fuels and (3) efficient 
energy conversion of biomass into electricity and heating and cooling. 

The  operational  objectives  are  to  establish  sustainability  requirements  for  solid  and  gaseous 
forms of biomass used in electricity and heating, as long as they are: 

– 

– 

– 

effective in dealing with problems of sustainable biomass use,  

cost-efficient in meeting the objectives and  

consistent with existing policies.  

38 

EN 

their 

World Bank (2004) estimates that 1.6 billion people around the world depend to some degree on forests 
http://www-
for 
wds.worldbank.org/servlet/WDSContentServer/WDSP/IB/2004/07/28/000009486_20040728090355/R
endered/PDF/297040v.1.pdf  

development 

"Sustaining 

livelihoods 

strategy", 

forests: 

a 

13 

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These objectives are consistent with the EU's climate and energy policy objectives, including 
the RES-Directive and the EU's energy efficiency action plan which aims to achieve a 20% 
energy saving by 2020 compared to business as usual. 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  the  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,  including  emissions  from  land  use  change). 
However, high GHG performance cannot guarantee that land is managed sustainably, or that 
the  efficiency  of  the  chain  improves,  as  inefficient  processes  can  also  lead  to  high  GHG 
performance. Therefore, all three issues are studied separately and the options under the three 
areas are not mutually exclusive.  

As far as the production phase of biomass in concerned, 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 assessment focus on the sustainability of production of 
forest biomass. As far as agricultural production practices in third countries is concerned, the 
RES Directive settled that these would be tackled through appropriate reporting 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 

Production 

A. 
biomass 

of 

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 

14 

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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.  

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 

(Section 5.1 elaborates the specific 
biodiversity and land use criteria) 

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. 

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) 

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 

As for A3 

As for A3 

Option A6: Option A3 
+ 
LULUCF 
accounting 

As Option A3, + evidence 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 

Option  B2:  labelling 
of GHG performance 

A1 and C1 (business as usual) 

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  

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.  

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. 

Option  B3:  Setting 
minimum 
GHG 
savings  requirements 
from 
for 
biomass 
and 
agriculture 

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 

15 

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- 

forestry 
35% 
(increasing  to  50-60% 
in 2017/2018)  

Option  B4:  minimum 
requirements 
GHG 
for 
and 
forest 
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 C3 if biomass pathways not able 
to meet minimum GHG threshold due 
to inefficient end-conversion 
technology.  

Partly A3 but does 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 
end-
lower 
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 
or 
inefficient 
use 
efficiency 
minimum 
large 
standards  (for 
scale 
installations 
above 1 MW) 

Option  C4:  labelling 
efficiency  

Option  C5*:  improve 
supply 
chain 
efficiency 

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.  

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. 

A GHG life cycle methodology to include 
end-conversion efficiency.  

Partly B3, B4 and B5 if the inefficient 
technology is responsible for not 
meeting the minimum GHG threshold  

B2 (labelling criteria) - GOs for 
instance could be used to disclose the 
GHG savings as well as the efficiency 
of a plant 

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 agricultural and forest land  

Annex  III  outlines  the  voluntary  actions  already  taken  to  ensure  sustainable  production  of 
biomass  in  the  forestry  agriculture  and  waste  sectors.  It  gives  an  indication  of  progress  and 
developments in the absence of new policy initiatives in this area.  

EN 

16 

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Option A1 would be no new EU action.  

Option  A2  (guidance)  would  have  the  effect  of  developing  specific  guidance  at  national  or 
European  level  on  dealing  with  the  effects  of  intensified  forest  management,  including 
harvesting  of  branches  and  leaves  and  stump  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  this  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  the  impacts  for  different  soil  types.  Intensified 
forest management can also have potential benefits, 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  establish  mandatory  "no-go  areas"  to  protect 
biodiversity or to prevent 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  policies,  notably  on  sustainability  criteria  for 
biofuels and bioliquids would cause any inconsistencies 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  would  need  to  be  adapted,  as  the  no-go  areas 
were developed with the purpose of avoiding undesirable 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  report  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 identified in certain areas, the Commission would 
propose  appropriate  corrective  action.  Two  options  for  further  action  are  possible:  a 
legislative  proposal  could  address  the  issue  following  monitoring  of  biomass  origin,  or 
appropriate corrective action could be included in the Directive covered by the present impact 
assessment. 

Option  A4b  (A3  +  reporting  on  SFM)  would  require  mandatory  reporting  on  sustainable 
forest  management.  At  EU  level,  the  Pan-European  Operational  Level  Guidelines  for 
Sustainable Forest Management could serve as a basis for the agreed principles and measures 
and reporting could be based on the criteria and indicators agreed by the 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 require 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  maintains  their  biodiversity,  productivity,  regeneration 

40 
41 
42 

Forest Research (April 2009) Stump harvesting guidance, sited at: http://www.forestresearch.gov.uk 
Organisms that feed on dead organic matter, especially fungus or bacterium 
19 other non-EU states are members and report on this basis to MCPFE 

EN 

17 

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capacity,  vitality  and  their  potential  to  fulfill,  now  and  in  the  future,  relevant  ecological, 
economic and social functions, at local, national, 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 indicators and criteria 
are defined locally. It is therefore not easy to find common thresholds 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-governmental responses identified in Annex IV.  

Furthermore,  studies  suggest  that  setting  common  rules  for  minimum  rules  for  SFM  are 
difficult,  given  the  climatic  differences  and  the  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 organic 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:  Biomass  (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 they are not readily applicable 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 forest regeneration is taken within x years. 

2. Obligations for measures in place to ensure viable population of forest-dependent species 

3.  Obligation  that  forest  biomass  extraction  must  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  account  would  need  to 
provide further evidence that the biomass comes from sustainable sources, as follows: 

SPECIFIC SITUATION: (cid:206) 

REQUIREMENT: 

Country of origin accounting under LULUCF  No requirement on operators (emissions from 

Country  of  origin  not  accounting  nor 
reporting under LULUCF 

LULUCF are accounted at national level) 

(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 carbon are uncertain by nature because 
they depend mostly on uncertain humus parameters 

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(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  emissions  related  to  energy  from  biomass  are 
counted as zero on the basis that emissions are 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  management.  Generally  speaking,  two  preferred 
accounting  options  have  emerged  within  the  EU  (although  several  more  are  still  under 
consideration in the UNFCCC negotiations). First, a 'bar'-approach based on a reference level 
against which net emissions and removals are compared. Second, gross-net accounting with a 
discount factor where net emissions and removals from forest management occurring during 
the commitment period are discounted by a predetermined factor in order to address LULUCF 
specific  issues  like  scale  effects  and  natural  disturbances.  The  bar-approach  maintains  full 
parity  with  non-LULUCF  mitigation  options  and  the  gross-net  accounting  with  a  discount 
factor has the advantage that net removals lead to credits and net emissions to debit, however 
net emissions in the LULUCF sector are discounted in comparison to emissions that occur in 
other  sectors.  This  gives  an  additional  incentive  to  the  use  of  forests  as  a  way  to  substitute 
fossil  fuel  rather  than  to  sequester  carbon.  Overall  the  effective  delivery  of  the  two  options 
with  respect  to  environmental  integrity  depends  on  the  way  they  are  implemented:  e.g.  the 
choice of discount factor and the 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  renewable  energy  targets  or  for  counting  as  zero-
carbon  emissions  under  ETS.  However,  the  Effort  Sharing  Decision  requires  that  the 
Commission  looks  into  whether  the  outcome  of  the  international  negotiations  on  LULUCF 
provides sufficient guarantees for the accounting of emissions from 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 imports of biomass. That is why 
the  option  of  incorporating  a  LULUCF  accounting  system  in  a  sustainability  scheme  for 
biomass  is  addressed  here,  in  order  to  assess  possible  requirements  that  could  allow  the 
Community  to  intervene  in  case  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 Directive 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.  

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The  RES  Directive  requires  biofuels  and  bioliquids  to  meet  a  35%  minimum  GHG 
requirement (35% 'threshold'). For biofuels, the extent 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  achieving  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  bio-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 used in electricity and heating applications 
(usually  above  80%  savings  as  compared  to  average  EU  fossil  heat  or  electricity),  it  would 
introduce unnecessary administrative burden to prove the GHG savings achieved.  

As most of the biomass used in electricity and heating is based on solid and gaseous biomass 
coming either from the forest or from agricultural residues (e.g. tree branches 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  (labelling)  would  not  require  the  introduction  of 
minimum GHG performance requirements. However Option B2 would enable consumers to 
know the GHG performance of electricity and heating 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  biomass44  used  for  energy  purposes.  This  would 
ensure  consistency  for  feedstocks  that  can  be  used  both  in  transport  (biofuels)  or  electricity 
and heat. Having the same threshold for all end uses would also avoid calculation problems 
when  allocating  GHG  emissions  to  heat  and  electricity  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 digestion 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-practice)  would  ensure  that  best  practice  is 
followed, as all biomass has the potential to improve GHG savings by utilising best practices. 
However the same methodological questions as under Option B3 would remain.  

4.1.3.  Policy  options  to  promote  efficient  resource  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  considers  one  factor  in  a  life-cycle  assessment,  the  energy 
conversion efficiency. Therefore the options on energy efficiency can be considered together 
with the options under production and GHG performance.  

44 

45 

Short rotation coppicing and plantations, such as palm are included in the consideration of agricultural 
biomass. 
Second  generation  biofuels  have  a  minimum  GHG  requirement  because  they  also  count  for  the 
purposes of the Fuel Quality Directive 2009/30/EC. 

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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  what  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  development  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  directive  proposed  by  the  Commission  end 
2008,  COM(2008)778,  in  particular  Article  9  on  public  procurement  and 
incentives, 

the  recast  of  the  Energy  performance  of  buildings  directive  proposed  by  the 
Commission  end  2008,  COM(2008)780,  in  particular  Article  8  related  to 
minimum energy performance requirements of technical building systems. 

These  policies  are  expected  to  improve  the  conversion  efficiency  of  (mainly)  residential 
boilers to a satisfactory extent, and no additional action is required for residential boilers46. 

Three  other  characteristic  stakeholder  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-alone 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 and respond rapidly to price 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  they  operate  one  or  several  stand-alone 
installations  that  produce  heat  and/or  electricity  from  biomass.  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 because 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  processes.  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 

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Depending on the user, different policy measures could be considered as effective or efficient 
in promoting higher energy conversion efficiency.  

Option  C1  (no  new  EU  action)  would  continue  to  rely  on  existing  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  obligations),  but  few  Member  States  currently 
explicitly consider the end-conversion of biomass installations in their policy. 

Option  C2  (bonus/  penalty)  allows  the  economic  operator  to  make  the  decision  on  the 
investment in the bio-energy installation to benefit 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 respond by shifting to more efficient options. If 
inefficient  processes  do  not  count  towards  targets,  Member  States  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 incentivise according to their national 
conditions and to respect subsidiarity. 

Option  C3  (minimum  efficiency  requirements)  would  exclude  the  application  of  certain 
biomass pathways or installations, but the decision not to use this pathway or installation does 
not  depend  on  an  economic  calculation  of  the  economic  operator  but  is  made  by  the 
government. Its effects can reach beyond support schemes, and in principle be applicable to 
all  biomass  conversion  installation.  If  commonly  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  those  cases  where  residue  streams  with  no  other 
purpose  (like  manure)  are  being  used  for  energy  production.  However,  this  risk  may  be 
eliminated if only the worst-performing technologies are banned. 

Option  C4  (labelling)  would  create  awareness,  appealing  to  the  environmentally  conscious 
and highlight cost saving through more efficient biomass use. It does not exclude the use of 
inefficient pathways or installations, nor does it create a financial incentive to take this aspect 
into  account.  Therefore,  the  labelling  of  end  conversion  efficiency  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  element  of  the  cost  calculations.  So  the  policy 
option  is  most  suitable  for  residential  boilers  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 

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The policy options have been screened for effectiveness, 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  harvesting.  The  UK  and  Swedish 
guidance  indicate  that  even  within  one  Member  State,  the  removal  of  stumps  would  have 
different effects on different 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 harvested forests absorb carbon dioxide faster than mature forest 
stands,  so  harvesting  them  for  energy  use  increases  the  CO2  uptake  from  the  atmosphere 
(Liski et al 200548). 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 large differences between 
countries  in  criteria  and  more  particularly  in  the  indicators  used  to  evaluate  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 extended to third countries, as 
third  countries  have  agreed  to  different  criteria  and  indicators  for  reporting  under  other 
intergovernmental initiatives. 

Option A6 is discarded because LULUCF accounting addresses the problems of accounting50 
for  biomass  emissions  and  not  the  problem  of  bad  practices  as  regards  unsustainable  forest 
management. The problem of balancing carbon stocks is not unique to the 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 bio-energy sustainability perspective, as this 
can provide only a partial policy response to make the LULUCF sector contribute to climate 
mitigation.  Instead  a  comprehensive  framework  may  be  needed  to  address  the  complex 
interactions  between  activities  in  the  sector.  More  importantly,  the  accounting  has  not  yet 
been agreed on, so it is not clear how carbon from forests would be accounted. 

48 

49 

50 

If the felling residues and thinnings are left in the forest, they initially add to the stock of carbon in the 
forest litter, but they rot away with a characteristic exponential 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 the 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. 
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  
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 the 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 are reported under the land use, land-use change and 
forestry category, therefore counting them under energy would constitute double counting. 

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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 effectiveness for improving the end-conversion efficiency 
is limited. This does not mean however that conversion to electricity and heat should not be 
part of the methodology. It is simply 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 include a particular type of impact, the findings of the Impact 
Assessment for the development of the sustainability 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  for  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 main 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 sustainable biomass production  

As set out in section 4, four options were retained for assessment: 

51 

SEC(2008)85 

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Option A1: no new EU action 

Option A3: criteria on biodiversity and land use  

Option A4a: Option A3 + reporting 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 outside 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 lands that are considered highly 
biodiverse: 

– 

– 

primary  forests  and  other  wooded  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 authority for nature protection 
purposes,  or  areas  designated  for  the  protection  of  rare,  threatened  or  endangered 
species  recognised  by  international  agreements  or  included  in  lists  drawn  up  by 
intergovernmental organisations 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  A3,  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 
53 

Eurostat 2007 data 
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 

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First,  stakeholders  said  that  there  are  instances  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 energy or other purposes instead of leaving them 
in the forest to degrade.  

Second,  stakeholders  argued  that  biodiversity  criteria  may  lead  to  the  value  of  timber  from 
bio-diverse forests to be devalued and 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  maintenance  of  biodiversity  are  also  taken  into 
account.  However  the  essence  of  primary  forests  is  that  they  are  undisturbed  by  man  and 
deserve  to  remain  protected  from  human  interference  even  if  they  are  subject  to  a  natural 
disaster.  In  fact,  the  presence  of  natural  disturbance  regimes  and  the  resulting  dead  and 
decomposing organic matter is the key attribute of such forest systems, and the main reason 
for their protection. The second 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 carbon 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 afford 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  also  included  in  the  proposed  calculation  of 
greenhouse gas emissions (see Annex V). Stakeholders in the public consultation pointed out 
that  when  converting  forests,  forest  biomass  can  still  count  towards  the  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  forests55  can  be  converted  to 
plantations without any penalty for land use change.  

To avoid negative land conversion of high carbon stock areas, it would be necessary that at 
least the land use criteria set in the RES Directive on land use should apply (as proposed by 
Option A3).  

It  should  be  considered  whether  further  reaching  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 

55 

This  is  the  case  of  Canada,  where  [x]  hectares  of  primary  forest  are  destroyed  due  to  pine  beetle 
infestation. 
A forest composed of indigenous trees and not classified as forest plantations 

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26 

   EN 

 
                                                 
principles  are  applied  in  production  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  collecting  information  on  the  origin  of  all  the 
biomass  used  for  heating  and  electricity  purposes  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 finds that forests are not regenerating in certain 
regions.  

Option  A5  would  go  further  than  reporting  and  require  minimum  requirements  for  SFM. 
Historically,  it  has  been  difficult  to  agree  common  SFM  standards  globally.  Four  possible 
minimum requirements (as identified in section 4) are considered.  

1)  A  requirement  for  economic  operators  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  already  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  biomass  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  area  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 amount of a viable population would need to be 
defined.  An  alternative  therefore  is  to  draw  up  lists  of  areas  for  the  protection  of  rare, 
threatened or endangered eco-systems or species. This is made possible under the biodiversity 
requirements in the Renewable Energy Directive, where such lists can be approved through a 
comitology procedure. It would therefore be achieved under Option A3. 

3)  A  requirement  for  forest  biomass  extraction  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 would 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 methods would need to 
be  developed.  Furthermore,  such  a  requirement  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  international  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  considered  as  cast-iron  measures  of  sustainability  but  as  evolving 
tools in an adaptive management system with the ultimate aim of sustainability. For all these 

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reasons,  it  would  be  undesirable  to  set  minimum  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  ensures  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 need to verify at least the origin of biomass i.e. 
the  chain  of  custody.  Using  the  EU's  Standard  Cost  Model,  the  COWI  Consortium 
distinguished  between  one-off  and  recurring  costs.  It  was  estimated  that  one-off  costs  are 
larger than recurring costs, based on the assumption 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 respectively56) 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 incurred depending on the minimum requirements 
for  SFM.  If  forest  vitality  would  be  a  minimum  requirement,  more  expensive  verification 
tools may be needed, requiring that the land is physically inspected. 

It  also  has  to  be  considered  whether  it  is  feasible  to  require  Member  States  to  verify 
compliance of household consumption of biomass. Households mainly use wood for heating 
purposes and often they procure wood from small local suppliers. Although the household-use 
of biomass is significant, it is considered that 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.  Monitoring  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  include  sample  and  questionnaire  size,  local 
per  diem,  and  salaries.  Eurostat  is  collecting  information  on  households  via  the  European 
Union  Statistics  on  Income  and  Living  Conditions  and  the  Household  Budget  Survey. 
Member  States  contribute  to  these  surveys  voluntarily.  Many  Member  States  also  have 
existing household surveys to which 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 economic operators under Options A3 and A4a are 
assumed  to  be  similar.  To  estimate  the  cost  of  providing  proof  of  the  origin  of  biomass 

56 

57 

The difference between low and high scenarios correspond to differences in the average EU wages for 
legislators and clerks 
O'Sullivan  K.,  Barnes  D.  (2006)  "Energy  Policies  and  multi-topic  household  surveys  ",  The  World 
Bank 

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through chain of custody (CoC) certification, under Options A3 and A4a, existing schemes in 
Europe were studied.  

In  Belgium,  electricity  producers  are  required  to  prove  the  sustainable  character  of  forestry 
resources in order to receive green certificates. Electrabel for instance, uses SGS Belgium as 
an  independent  body  to  check  the  biomass  supply  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 documents 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  "Biomass  Supplier  Declaration",  which  is  6  pages, 
consisting  of  declaration  of  the  wood  origin,  the  production  chain,  including  energy 
consumption,  and  transportation  and  storage.  Since  2003,  75  suppliers  have  been  audited, 
including  in  Brazil,  South  Africa,  Malaysia  and  North  America  (SGS  Presentation,  EU 
Sustainable  Energy  Week  2009).  According  to  Laborelec,  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)  certification  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  indirect  costs).  This  is  equivalent  to  around  €0.01-0.38/  ton58 
and these costs were estimated for larger forest 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 due to the size of the certified area. 

The estimated cost for SFM certification (Option 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 industry and traders as well as energy 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 reassessment 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-off costs for biomass producers in the EU-27 
to be between €0.2-6.7 million and recurring costs €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)  assessed  whether  sustainability  criteria  on  land  use  and 
biodiversity (as in Options A3, A4a and A5) would have any impact on economic availability 

58 
59 

60 

61 

Based on 3m3/ha and 0.7 tonne/m3 
Even the 100 ha average holding could still be considered large in overall EU terms. The EU average 
holding is about 10 Ha but many Member States have millions of much smaller units. In Greece, forest 
ownerships are measured in Stremmae (0.1 Ha). 
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.  
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 

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of  biomass.  The  scenarios  from  the  consulted  literature,  that  take  into  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 sustainability 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. However, 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  exclusion  criteria  as  laid  down  in  the  RES  Directive. 
Given  the  ratio  between  projected  availability  and  the  9  Mtoe  projected  in  GREEN-X  by 
2020, it could be concluded that there will be sufficient forestry material available for import 
that does meet the land exclusion criteria. Even if imports of pellets projected to be 33 Mtoe 
by AEBIOM are realised, this is still a small share of the available range identified above.  

Agricultural  crops:  Biofuels  and  bioliquids  are  already  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  rapeseed,  2  Mtoe  soy,  2  Mtoe  palm  and  2,5  Mtoe 
bioethanol. The IEA Bioenergy Review projects a production potential 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, 200864), 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  specified.  Again,  it  should  be  stressed  that  these 
availability estimations strongly depend on developments in agricultural productivity, animal 
husbandry and food consumption. However, the current global trade volumes 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 verification 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 employment. Employment opportunities would arise under Option A5, 
as not only biomass origin but also the sustainable management of forests would need to be 

62 

63 

64 

65 

EEA  (2007a):  Environmentally  compatible  bio-energy  potential  from  European  forests.  Copenhagen, 
European Environment Agency 
IEA  (2009):  Bioenergy  -  A  review  of  status  and  prospects.  Paris,  Bioenergy  Agreement  of  the 
International Energy Agency 
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. 
Thoenes, P. (2006): Biofuels and Commodity Markets – Palm Oil Focus. Rome, United Nations Food 
and Agriculture Organisation 

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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  criteria  are  those  that  already  export  solid 
biomass to the EU. Although it is difficult to obtain information about biomass traded, some 
assessments  suggest  that  most  of  Europe's  imports  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  affected  is  highly  uncertain.  It  is  however 
possible to assume that the administrative costs per economic operator will 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 

A3: 
on 

Option 
criteria 
biodiversity 
and land use 

Option  A4a: 
Option  A3  + 
mandatory 
reporting 
on 
biomass origin  

0 
No effect 

0 
No effect 

- 
Proof of 
origin of 
biomass 
will incur 
some costs 
in 
developing 
tracing 
mechanism
s 
- 
Proof of 
origin of 
biomass 
incurs costs 
in 
developing 
tracing 
mechanism
s 

- 
Some costs 
due to 
verifying 
claims on 
biomass 
origin and 
household 
surveys 

- 
Some cost 
due to 
verifying 
claims on 
biomass 
origin, 
household 
surveys and 
formalising 
reporting on 
SFM 

0 
Does not minimise 
risk of loss of 
biodiverse or high 
carbon stock land  
+ 
Protection for highly 
bio-diverse and high 
carbon-stock areas  

0 
No effect 

0 
No effect 

0 
No effect 

0 
No effect 

+ 
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 

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Costs to 
public 
administrati
on (EU-27) 

-- 
Costs of 
setting up 
verification 
tools 

Economic 
availability 
of biomass 

Costs to 
economic 
operators  

Environmental 
impacts 

Biodiversity and 
Land use  

Employment  Households 

0 
No effect 

-- 
Increased 
certification 
or auditing 
cost  

++ 
Protection of highly 
biodiverse and high 
carbon stock areas 
and promotes SFM 

0 
No effect 

+ 
Additional 
jobs for 
certification 
and 
verification 

A5: 
Option 
Option  A3  + 
SFM obligation 

Table  2  shows  that  Option  A1  does  not  minimise  negative  environmental  impacts.  An 
argument  in  support  of  Option  A1  however  is  that  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 and A4a have similar environmental impacts, as 
reporting requirements are not able to serve as a precautionary 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  public  authorities  and  economic 
operators. Options A3 and A4a can be achieved at a reasonably low cost, given that Member 
States are obliged under the RES Directive to develop verification  methods for  determining 
the  origin  of  biomass  used  to  produce  biofuels  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.  This  is  because  the  estimated 
economic potentials of biomass in 2020 already exclude highly biodiverse areas.  

5.2. 

Policy options to ensure greenhouse 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  impacts  of  bioenergy  pathways,  a  methodology  is 
needed  to  calculate  GHG  emissions  incurred  through  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  significant  divergence  in 
results.  In  designing  the  greenhouse  gas  methodology  used  in  the  RES  Directive,  the 
Commission  brought  together  representatives  of  the  biofuels  and  agricultural  sectors  with 
JRC, CONCAWE and EUCAR to work intensively on the methodological issues (as well as 
data  improvements).  The  methodology  agreed  was  to  take  into  account  greenhouse  gas 
emissions  throughout  the  processes  of  production  and  use  of  fuels,  including  the  effects  of 
land use change.  

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It is proposed to build on the existing methodology in the RES Directive, but as "final energy" 
in the case of biomass implies heat or electricity, 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 conversion efficiency for larger energy facilities.  

If minimum emissions savings are to be agreed, it is proposed to compare the GHG emissions 
to the emissions of the average fossil fuel plant at EU level. EU-wide figures 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  gas  performance  from  solid  and  gaseous  biomass  used  in 
electricity and heating, the Joint Research Centre (JRC) was asked to  develop pathways for 
several  different  uses  of  biomass,  e.g.  pellets,  charcoal  etc.,  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  and  pellets  used  in  electricity  and  heating67 
(losses  for  energy  conversion  are  included,  based  on  assumptions  of  25%  electrical 
conversion efficiency, and 85% thermal conversion efficiency).  

67 

Source  JRC,  2009  [Typical  values  can  be  estimated  at  the  mid-points  of  ranges,  but  it  cannot  be 
excluded that production processes are sometimes worse than these typical values.] 

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Graph 1: GHG savings potential of solid biomass used in electricity and heating 

GHG savings from solid biomass used in electricity and heating

Electricity

Heat

%
s
g
n
i
v
a
s
G
H
G

)
l
e
u
f

l
i
s
s
o
f

U
E
o
t
d
e
r
a
p
m
o
c
(

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

FR pellets (EU NG process fuel) 
FR pellets (EU/wood process fuel) 
FR pellets (tropical/NG process fuel)
FR charcoal (EU)
FR chips (EU)
FR chips (tropical)
FR charcoal (tropical)
FR pellets (tropical/wood process fuel)
Bagasse briquettes (NG process fuel)
wheat straw (EU)
Bagasse briquettes (wood process fuel)

Bagasse bales

Palm kernel shells

SRC pellets (EU/ NG as process fuel)
SRC pellets (tropical/ NG as process fuel)
SRC chips (EU)
SRC pellets (EU/ wood process fuel)
SRC chips (tropical)
Miscanthus
SRC pellets (tropical/ wood process fuel)

solid biomass feedstocks

*SRC refers to short rotation coppicing 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 greenhouse gas savings (compared to fossil alternatives). Pellets 
from processed forest residues (i.e. post-processing) 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 imagine black liquor being sold outside the pulp mill. 
It is therefore considered as a waste.  

In these calculations, land use emissions are assumed 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  this  can  normally  be  expected  to  be  the  case, 
especially as the EU is experiencing afforestation rather than deforestation. 

The  greenhouse  gas  emissions  performance  figures  for  forest  biomass  are  supported  by  the 
UK's Environment Agency report69, 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  compared  to  natural 
gas71).  In  the  RES  Directive  default  values  were  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  emissions  is  small.  These  default  values  were 

68 

69 
70 
71 

Pellets (and charcoal) are normally produced from sawmill residues (not short rotation coppicing) as a 
high level of dryness and bark removal is required.  
Environment Agency (2009) "Minimising greenhouse gas emissions from biomass energy generation" 
Short rotation coppicing is considered as agriculture in this analysis, as usually arable land is used. 
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 

34 

   EN 

 
 
 
 
 
 
 
 
 
                                                 
calculated by increasing the assumed emissions from production by 40%. As the production 
emissions  is  routinely  low  (below  1g  CO2eq/MJ  biomass  for  forest  residues  (FR)  and 
between  2-6g  CO2eq/MJ  for  wood  from  short  rotation  forestry  (SRC)),  the  default  value 
would still in most cases lead to above 80% savings.  

It  could  be  argued  that  some  of  the  possible  greenhouse  gas  emissions  saving  opportunities 
are already tackled elsewhere. In case of municipal solid waste, under the Waste Framework 
Directive,  waste  incinerator  operators  have  to  meet  a  given  energy  efficiency  threshold. 
Moreover, there are also incentives to reduce GHG emission in general through the ETS and 
the  GHG  reduction  targets  agreed.  Nevertheless  those  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  savings  (compared  to  fossil  alternatives).  In 
these calculations, land use emissions are assumed to be zero, as in the case of forest or waste 
biomass, the assumption is that no land conversion is taking place to produce the biomass. As 
stated  above,  this  can  be  expected  to  be  the  case,  especially  as  the  EU  is  experiencing 
afforestation rather than deforestation. 

Given the data above, Options B2 would not lead to additional GHG savings.  

Option B3 will lead to between 5-20% additional 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  feedstocks  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 (barbeques) in the EU. It is not likely that putting 
minimum GHG requirements on charcoal would deliver 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-Directive  and  provides  consistency  for  those 
feedstocks  that  can  be  used  both  for  transport  purposes  (biofuels)  and  for  electricity  and 
heating, such as straw, energy grasses and energy crops. 

Option  B4  will  lead  to  some  additional  GHG  savings  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  process  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 operators would have to 
be checked.  

72 

Trade in charcoal from Africa to the EU is not significant, however. The largest importers of charcoal in 
the EU (Germany, Poland, Spain, Bulgaria and UK) source charcoal mainly from other countries inside 
the  EU  (the  largest  exporters  of  charcoal  are  Poland,  France  and  Germany).  The  largest  exporters  to 
Europe are Malaysia and Indonesia. The largest exporter from Africa is South Africa which does have 
strong policies on reforestation and forest management. 

EN 

35 

   EN 

 
                                                 
The  cost  for  Options  B3  and  B4  were  calculated  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 

One-off costs 

Recurring costs 

 Low cost 
scenario 
(€/year) 
€0.3 
million 
€0.1 million 

High cost 
scenario 
(€/year) 

€1.1 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 differences in processing of feedstocks, an option is 
to develop default values for pathways using natural 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 different processes are reflected. 

b. Costs to economic operators 

Under the RES Directive, economic operators are required to use the mass balance method73 
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  was  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 chain75. 

The COWI Consortium (2009) found that the cost of GHG certification is substantially higher 
when economic operators have to show actual 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  processors,  manufactures,  traders  and  energy  producers, 
the recurring costs are 60-70% higher when GHG certification is imposed compared to CoC 
certification  alone.  One-off  costs  were  unaffected.  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 million 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 

74 
75 

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 targets. 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. 
Based on 1 tonne = 0.3215 toe 
For  forest  residues,  plants  in  general  receive  their  individual  biomass  loads  directly  from  a  supplier, 
even where independent biomass suppliers organise the purchase. 

EN 

36 

   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 all electricity and heat plants from 2017-2018. 

In order to derive the total economic availability of biomass in 2020 for Option B3, it needs to 
be considered which agricultural biomass pathways (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  possible  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 CO2 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 CO2 emissions in the biofuel processing 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 processing, as these are mainly attributed 
to  methane  slip  in  the  gas  engine  which  can  be  well  avoided  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-distance 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  and  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 chain that falls short of the 2017 (existing plants) 
50% threshold is: 

– 

Biodiesel from soy 

The biofuel chains that fall short of the 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 

37 

   EN 

 
                                                 
–  Wheat ethanol with natural gas (conventional 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 

Typical GHG 
reduction 

(%) 

(%) 2017 

(%) 2018 new 

Bioethanol (1st generation) 

Wheat 

- lignite as process fuel in CHP  

- natural gas as process fuel in conventional 
boiler 

32% 

45% 

41% 

53% 

42% 

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 

- Soy bean 

- Palm oil (process not specified) 

Hydrotreated vegetable oil 

- Rape seed 

- Palm oil (process not specified) 

Pure vegetable oil 

- Rape seed 

Electricity and heat pathways 

- Power only on vegetable oils: soy 

-  Power  only  on  vegetable  oils:  palm  (no 
CH4 cap) 

45% 

40% 

36% 

51% 

40% 

54% 

43% 

38% 

60% 

45% 

55% 

44% 

40% 

61% 

47% 

59% 

67% 

68% 

51% 

44% 

56% 

53% 

58% 

55% 

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38 

   EN 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
It can be seen from Table 4 that for non-biofuels, only the power generation options on the 
basis of soy and palm (process not specified) fall short of the 60% threshold. 

However, it is important to consider the overall 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 targets 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  straightforward  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  option  would  be  the  introduction  of  biomethanol 
instead of fossil methanol (detailed data are specified in the COWI Consortium 2009 study). 
This option leads to a typical GHG reduction of 62%. For soy biodiesel, additional options to 
improve the GHG profile seem to be insufficient to meet the 50% and the 60% threshold. For 
existing  installations  by  2017,  the  50%  threshold  can  be  met  by  the  introduction  of 
biomethanol instead of fossil methanol; it leads 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 capture) that do not meet the 50% and/or 60% 
threshold,  it  can  be  foreseen  that  methane  capture  will  be  implemented,  which  can  be  done 
relatively cost-effectively. This leads to a typical 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 from mills with methane capture. This increases 
the greenhouse gas emission reduction to 75%.  

The  impacts  of  carrying  out  these  improvements  were  assessed  by  the  COWI  Consortium 
(2009).  Table  5  summarises  these  costs.  All  costs  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 
wheat 
boiler) 

from 
(NG 

54% (2018) 

Shift 
natual 
CHP 

to 
gas 

62% 
(2018) 

0 

0 

EN 

39 

   EN 

 
Biodiesel 
rapeseed 

from 

55% (2018) 

Biodiesel 
soy 

from 

43% (2017) 

Biomethanol 
in 
processing 

62% 
(2018) 

Biomethanol 
in 
processing 

50% 
(2017) 

13 M€ 

0 

18 M€ 

23 M€ 

Biodiesel 
soy 

from 

44% (2018) 

Shift to rape, 
sunflower 

>62% 
(2018) 

15 M€ 

0 

Biodiesel/HVO 
from 
(p.n.s.) 

palm 

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 typical values for respectively biodiesel and HVO from palm 
with methane capture at oil mill. 2017 and 2018 values have not been calculated but will be 
above these values. 

A full shift to methane capture in palm oil production comes at an estimated 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  compliance  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  availability  of  biomass,  as  it  is 
assumed  that  high  GHG  requirements  for  forest  biomass  can  be  achieved  by  the  sector. 
However,  the  additional  compliance  costs  associated  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 obligations could be reasonably put on households, as 
it  would  be  difficult  to  monitor  their  GHG  savings.  If  households  are  exempted  from  these 
requirements,  there  is  no  impact  on  households.  Employment  effects  are  also  considered 
negligible from putting in place greenhouse 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  affected  is  highly  uncertain.  It  is  however 
possible to assume that the administrative costs per economic operator will be similar to those 
calculated  for  EU  actors.  The  COWI  Consortium  calculated  costs  for  forest  owners  and 
farmers  producing  short  rotation  coppicing,  as  well  as  for  wood  processors  manufacturing 
secondary woodfuels or raw materials for these (saw mills, pulp and paper mills, pellet and 

EN 

40 

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briquette factories) and biomass traders. The costs for these target groups are detailed in the 
COWI Consortium's report, and are summarised below:  

Table 6: Administrative costs of GHG verification per biomass producer/ processors 
and traders 

Type of costs 

One-off costs 
Recurring costs 

Biomass 
producers  
€205-820 
€769-3076/ 
year 

Processors and 
traders 
€205-820 
€898-3593/ 
year 

Some third country producers, such as pellet factories, already provide evidence of meeting 
CO2 performance requirements, e.g. under company 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 

B2: 
of 

Option 
labelling 
GHG 
performance 

0 
No effect 

- 
Costs to set up 
scheme and 
provide 
labelling 

0 
No 
effect 

0 
No 
effect 

0 
No effect 

- 
Some additional 
costs for labelling 
scheme 

- 
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 

B3: 

Option 
35% 
(increasing  to 
50-60% 
in 
2017/2018) 
GHG  savings 
for 
agricultural  + 
forestry 
pathways 

0 
No 
effect 

0 
No 
effect 

0 
No 
effect 

0 
No 
effect 

0  
No 
effect  

0  
No 
effect  

0 
Does not contribute to 
additional GHG savings  

0 
No significant benefit, as 
differences in GHG 
performance are difficult 
to distinguish for most 
consumers of heat/ 
electricity 
+ 
Some additional GHG 
savings (5% for biogas 
based on crops and 5-
20% for SRC charcoal 
and 5-10% for charcoal 
from forest residues) 

B4: 

in 

GHG 

Option 
GHG 
thresholds 
accordance 
with 
saving 
potential 
(except 
waste 

for 

- 
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  

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41 

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biomass) 

Table  7  shows  that  that  Options  B3  and  B4  would  bring  some  additional  environmental 
benefits in terms of GHG performance. 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 minimum standards set. In particular, 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  life  cycle  are  not  immensely  significant  for 
Option B3 and B4. In particular, the additional burden of having different GHG requirements 
for  different  pathways  (Option  B4)  may  not  outweigh  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  lifecycle.  Administrative  costs  are  reduced  if 
the GHG requirements are consistent over all biomass feedstocks (whether used as transport 
biofuels  or  for  electricity  and  heat),  as  proposed  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  depending  on  the  process  fuel.  This  would  limit  the 
administrative burden while ensuring that differences in emissions due to different processes 
are reflected. 

5.3 

Policy Options to foster higher end-conversion efficiency of biomass 

Option C1: No new EU action 

Option C2: Bonus for better end-conversion efficiency or penalty for lower end-conversion efficiency 

Option C3: Minimum efficiency standards 

Policy options for different technology combinations 

The  policy  options  will  produce  very  different  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.  Most  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 performance 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 produced. Therefore a specific attention on using 
heat  in  the  bonus  system  could  be  considered.  In  Belgium  for  instance,  in  the  Walloon  and 
Brussels  regions,  subsidies  are  granted  based  upon  the  avoided  fossil  CO2  emissions  with 
respect to a reference fossil plant, based on an LCA analysis, including the efficiency of the 
plant77. This means that biomass is not considered as fully CO2 neutral for the purposes of the 
Green certificate scheme, and in many cases power-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 

42 

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Minimum  performance  standards for new  installations might  also  be feasible, 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.  Under  the  Eco-design 
Directive,  the  Commission  has  already  undertaken  a  study  on  the  energy  efficiency  of 
industrial  ovens  and  furnaces  that  will  cover  all  potential  fuel  sources,  including  biomass. 
Results of this study will be available at the end of 2011.  

Labelling is not a feasible policy option for large 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.  Setting  minimum  requirements  for  installations  using  biomass 
and not for other fossil fuels, may lead to decreased use of biomass in co-firing plants. Energy 
efficiency  policies  looking  at  all  fuels  therefore  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  generation  but  waste  management.  Setting  minimum 
efficiency  requirements  for  biodegradable  wastes  might  therefore  result  in  reducing  the 
potential  of  green  electricity  produced  from  a  feedstock 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  installation  due  to  technical  performances  and  process 
management.  The  Waste  Framework  Directive  also  has  some  incentives  for  improving 
efficiency.  It  sets  minimum  efficiency  requirements  to  serve  as  a  threshold  for  the 
classification of waste incineration 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-wastes, energy is produced and the digestate is 
a  more  valuable  fertilizer  than  the  manure  itself.  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  environmental  advantages  (and  waste  management 
objectives). Therefore for waste digestion the most suitable policy option would be a bonus/ 
penalty system.  

District  heating  systems  are  more  efficient  than  individual  heating  systems  therefore 
stimulation of those systems would increase efficiency. However the construction 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 and different policy options relevant 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  possible  efficiency  improvements  of  the  different  biomass 
technology combinations and summarises the possible policy options to be used to stimulate 
increased end-conversion efficiency of the different technology combinations.  

EN 

43 

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Table 8 (from Ecorys report 2009, table 21): Summary of biomass technology 
combinations and their improved efficiency potentials 

Typical 
efficienc
y % 

Main 
countries 
of 
applicatio
n 

of 

Order 
magnitude 
of  estimated 
current 
capacity 

Order 
magnitude 
estimate of 

of 

Efficiency 
improvement
s  

Possible  policy 
options 

maximum 
potential 

Large 
power 
CHP  

scale 
and 

FI, DK, SE, 
EE, 
LV, 
LT, AT 

10-30 
electrical 

4.7GWe  

5.8 MWe 

unknown 
of 

(+ 
amount 
heat) 

at ηe=20%->25% 

15 GWth at full heat 
utilization 

Co-firing 

DE, 
UK, NL 

FI, 

 35-43 
electrical 

1.2 GWe 

8.3  GWe  based  on 
total 
technical 
potential 

Large 
scale; 
heat utilization; 

-Improved  heat 
by 
Recovery 
ORC  of 
flue 
gas condenser 

Heat utilization 

-(Improve 
impact: 
increase market 
penetration) 

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 

-Minimum 
efficiency 
standard 

specific 
-No 
efficiency  related 
policies 

is 
-Efficiency 
already high, with 
possibilities 
for 
stimulation of co-
firing in general 

-  Bonus/  penalty 
system 
for 
efficiency 
improvement 

Power 
ORC 

Plant 

AT, DE 

6-20 
electrical 

Unknown 

Unknown 

District 
heating 

SE, FI, DK, 
EE, 
LV, 
AT 

80-90 
thermal 

126 GWth 

Improving 
efficiency 
ηth80%->90% 
reduces 
energy 

from 

primary 

Manure 
(co)digestion 

DE,  DK, 
AT,  NL, 
IT, PT, HU 

Not 
relevant 
(motor: 
38-42 

1667 MWe 

consumption  with 
26PJ->14.4  GWth 
installed capacity 

2037MWth 
(at 
electrical  efficiency 
of 36%); 1852 MWe 
and  1852  MWth 
electrical 
when 

-Autonomous 
improvement 
of 
technology 

this  new 

-Bonus/  penalty 
system 
for 
efficiency 
improvement 

-Minimum 
efficiency 
standard 

-Investment 
Subsidy 

-Minimum 
efficiency 
standard 

-Improved  heat 
by 
recovery 
e.g. 
flue  gas 
condensation; 

-Boiler 
efficiency 
improvements 

-Heat 
utilization; 

-Avoid 
scale 

small 
gas 

-Bonus/  penalty 
system 
for 
efficiency 
improvement 

EN 

44 

   EN 

 
 
 
electrical) 

efficiency 
(scale advantages) 

is  40% 

engines 

Diesel  engines 
on  vegetable 
oils 

IT, DE 

40-48 
electrical 

Unknown 

Unknown 

-Heat 
utilization; 

-Avoid 
scale 
engines 

small 
diesel 

-Bonus/  penalty 
system 
for 
efficiency 
improvement 

-Minimum 
efficiency 
standard 

Option  C2  (Bonus/  penalty  system)  is  best  applicable  where  significant  improvements  in 
efficiency can be made, due to the costs for government. In this sense, stimulation of heat & 
power  production  over  stand-alone  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  step-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: such as waste treatment, as minimum efficiency 
requirements may hamper the supply of the main service of such plants.  

Option C3 (minimum efficiency standards) is effective 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 minimum 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 which 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 savings 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-conversion efficiency improvements of existing plants 
depends  on  what  the  biomass  technologies  are  being  compared  to.  When  compared  with 
similar size fossil fuel plants, there are hardly 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  fuels.  In  that  case,  positive  impacts  would  be 
dependent  on  the  effectiveness  of  the  different  policy  options  to  replace  fossil  fuel 
alternatives.  

Table 7 in section 5.3.1 shows the range of efficiency improvements achievable by different 
technology  combinations  (typical  efficiency).  The  biggest  improvements  could  come  from 
utilising the heat in electricity only plants (i.e. switching to biomass CHP).  

EN 

45 

   EN 

 
Therefore  policies  which  can  encourage  these  improvements  will  have  the  highest 
environmental benefits.  

Under Option C3, if minimum efficiency standards 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 premium 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 which is achievable for the 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.  Ecorys  estimated  administrative 
costs using the EU standard cost model (See Ecorys 2009).  

 Total Administrative Costs 

No. 

C2a 

Type of obligation 

Bonus/ penalty system for large-
scale power and CHP 

C2b  Bonus/ penalty system for waste 

incineration 
Bonus/ penalty system for co-
digestion 
Minimum efficiency standard for 
large scale power and CHP 
Minimum efficiency standard for 
district heating 

C2c 

C3b 

C3c 

 Low cost 
scenario 

High cost 
scenario 

€592,463 

€2,369,852 

€404,240 

€1,616,960 

€443,264 

€1,773,056 

€695,217 

€2,780,868 

€934,573 

€3,738,293 

For  Option  C2,  there  may  be  additional  costs  to  governments.  This  could  depend  on  the 
support scheme used in Member States. In Austria, the support framework for highly efficient 
renewable electricity production is provided through the "Eco-Power Act" in 2003 which lays 
down criteria for energy efficiency (investments for installation of the heat extraction part are 
subsidised depending on the ensured heat extraction with 15%–30% of the investment cost), 
and provides a purchasing obligation and tariff support, which are funded via an extra charge 
on  the  electricity  price.78  (Electricity  prices  for  households  have  increased  from  €13.19/ 
100kWh in 2004 to €14.09/kWh in 200779).  

b. Costs to economic operators 

78 

79 

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/ 
Eurostat, taxes included 

EN 

46 

   EN 

 
                                                 
The  cost  of  increasing  efficiencies  of  the  different  types  of  biomass  plants  was  studied  by 
Ecorys  (2009).  In  general,  improvements  in  end-conversion  efficiency  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 make 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  installations  generating  bioenergy  obviously  makes  it 
difficult to give a reliable indication of these costs. 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  force  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  legislation.  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  installations.  Nevertheless,  an  option  for  minimum 
efficiency  requirements,  which  would  require  the  use  of  heat,  would  lead  to  considerable 
compliance costs, between €50-200 million per installation. 

c. Economic availability of biomass 

The  impacts  on  availability  of  biomass  are  deduced  from  the  total  savings  of  replacing 
efficient  technologies  with  inefficient  ones.  The  baseline  scenario  already  takes  account  of 
increases in efficiency, through technology learning. If any impact arises, it is likely 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 

47 

   EN 

 
                                                 
money for consumption is shifted from other goods to the consumption of energy. However, 
if  the  additional  investment,  maintenance  and  operation  for  biomass  induce  more 
employment, the households will have more money available for consumption (total income 
of  household  increases).  This  might  compensate  the  negative  price  effect  and  increase 
consumption. 

b. Employment 

Employment impacts can arise where the minimum efficiency requirements under Option C3 
result  in  a  need  for  upgrading  systems.  An  increase  in  investments  increases  the  demand  in 
biomass  related  services  and  biomass-technology  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  like  the  forest  and  agricultural  sectors,  transportation  sector 
etc. Besides the suppliers of the biomass technology producing sector, we also have to take 
into  account  the  effect  of  biomass  promotion  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 and employment will decrease at conventional 
(fossil)  energy  technology  producers  and  service  providers  as  well  as  at  the  suppliers  of 
technology producers.  

The employment effects are not expected to be significant, as the technological improvements 
needed  to  reach  the  2020  targets  have  already  been  considered  studying  the  baseline.  Only 
where  there  are  minimum  efficiency  standards  introduced  could  some  positive  employment 
effects  arise,  given  that  the  efficiency  standards  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 policy options to foster 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 

Option C2: 
Bonus  for 
better  end-
conversion 
efficiency 
or  penalty 
for 
lower 
end-
conversion 
efficiency 

0 
No effect 

0 
No effect 

0 
No effect 

0 
No effect  

0 
No effect 

0 
No effect 

- 
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. 

0 
No effect 

+  
leads to more 
effective use 
of resources 

+ 
More efficient 
burning of 
biomass leads to 
less quantity of 
biomass used 
per energy 
produced 

0 
Some 
additional 
jobs from 
investments 
effects, but 
the impacts 
are 
negligible 

Option C3: 

-- 
High costs of 

-- 
High 

+ 
More efficient 

Depends on 
response to 

+ 
Additional 

- 
Increased 

EN 

48 

   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 

jobs from 
investment 
effects 

energy costs 
on 
consumers 

+ when a 
standard leads 
to more 
effective use 
of resources 

Table 9 shows that option C1 has no effect on further improving end conversion efficiency. 
The environmental impacts of Options C3 depend on wider energy efficiency policy for fossil 
alternatives. Negative impacts can occur where the 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.  Option  C2  (bonus/  penalty)  could  be  costly  to 
governments, but it is the effective option in terms of delivering environmental benefits, while 
ensuring low compliance costs.  

EN 

49 

   EN 

 
 
 
 
 
Section 6: Comparing the options 

The options can be compared in accordance 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 depending  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  there  is  a  maximum  potential  of 
biomass feedstocks, to avoid overuse of the resource.  

- costs-efficiency: costs to public administration and economic operators should not outweigh 
the  sustainability  benefits,  i.e.  there  should  be  proportionality  in  putting  burden  on 
administrations  and  industry.  Burden  is  proportionate  if  real  improvements  in  sustainability 
can be made.  

The impacts of the different options can be compared as follows: 

Legend: 

Positive effect 

Moderate effect 

Negative effect 

Not relevant X 

Effectiveness 
achieving objectives 

in 

Efficiency  

Consistency 

(cost-effectiveness) 

(with  policy  structures  and 
socio-economic 
developments) 

Option A1: no new EU action 

in  avoiding 
Ineffective 
negative land use changes  

Not relevant 

Inconsistent  with  biofuels 
policy  

A3: 

Option 
biodiversity  and 
criteria  

minimum 
land  use 

Effective 
ensuring 
in 
further  safeguards  against 
negative land use changes 

Option  A4a:  Option  A3  + 
mandatory 
and 
monitoring SFM  

reporting 

Effective 
ensuring 
in 
further  safeguards  against 
negative  land  use  changes 
and  effective  in  informing 
decision-makers 
about 
future trends 

X 

costs 
Administrative 
minimised 
as  verification 
scheme  for  origin  of  biomass 
is 
required  under  RES-
Directive  

Administrative  costs  can  be 
minimized  where  reporting  is 
based  on  existing  voluntary 
reporting tools (e.g. MCPFE) 

Consistent  with 
policy 

biofuels 

Consistent  with  biofuels  and 
with global SFM policies 

Option  A5:  Option  A3  + 
SFM obligation 

avoiding 
in 
Effective 
negative  land  use  impacts 

High  administrative  costs  for 
monitoring implementation of 

Consistent  with  EU  policy 
tackle 
objectives 

to 

EN 

50 

   EN 

 
 
 
 
Effectiveness 
achieving objectives 

in 

Efficiency  

Consistency 

(cost-effectiveness) 

as well as ensuring SFM 

SFM 
certification of SFM 

criteria 

and 

Option B1: no new EU action  May lead to some biomass 
pathways  not  achieving 
high GHG performance 

Not relevant 

X 

(with  policy  structures  and 
socio-economic 
developments) 

for 

deforestation 
degradation 

and 

forest 

Inconsistency  of  accounting 
for 
emissions 
GHG 
agricultural  biomass  under 
the RED  

Option B2: labelling of GHG 
performance 

only 

Effective 
for 
consumer  products  not 
large scale plants  

Some costs to administrations 
and to economic operators 

Not relevant 

X 

Option  B3:  minimum  GHG 
for 
savings 
agricultural 
forestry 
pathways  of  35%  (increasing 
to 50-60% in 2017/2018)  

threshold 
and 

Option  B4:  Minimum  GHG 
in  accordance 
performance 
with  GHG 
performance 
potential  (except  for  waste 
biomass) 

avoiding 
in 
Effective 
pathways  with  low  GHG 
performance 

Some costs for verification of 
GHG performance  

Consistent  with 
policy 

biofuels 

Effective 
worst 
lowering GHG emissions 

in 
practices 

avoiding 
and 

Some costs for verification of 
GHG performance 

with 

Consistent 
GHG 
emissions  reduction  policy, 
but  not  with  biofuels  policy 
generation 
e.g. 
biofuels 

second 

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 

Option C3 - Minimum 

Effective in excluding 

efficiency 

performance 

standards 

poor performing 

installations,  but  difficult 
to set 

unambiguous thresholds 

High  compliance  costs 
to 
economic operators if applied 
to existing installations 

in 

existing  policy  framework 
line  with  general 
and 
approach 
to  reward  good 
behaviour 

Requires  development  of 
new  policy  instrument  and 
may  conflict  with  aims  of 
other  policies  (promotion  of 
renewables  vs  fossil,  waste 
treatment, 
rural 
security  of 
development, 
supply) 

On the production side, in the light of the analysis summarised above, the policy option for 
putting  in  place  minimum  requirements  for  avoidance  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-efficiency 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  used  for  energy  purposes  is  recommended,  to 

EN 

51 

   EN 

 
 
 
 
 
 
 
 
 
 
improve statistics on biomass  use  and  to monitor the effects of biomass 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,  through  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 accounting for LULUCF emissions could serve as 
one of the factors in monitoring. For biomass used in households, Member States can monitor 
the use of biomass through surveys.  

As regards greenhouse gas performance, it is recommended that for consistency operators use 
an  EU-wide  harmonised  GHG  methodology  to  calculate  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 however that wastes and processing residues which 
routinely  achieve  high  greenhouse  gas  savings  should  not  be  required  to  reach  these 
requirements,  as  including  them  would  not  afford  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  them.  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 difficult to set the right incentives without thinking 
about  the  technology  that  it  will  be  applied  to.  The  assessment  shows  that  efficiencies  of 
different technologies cannot be compared (because often they serve different purposes, e.g. 
waste  management)  and  that  all  technologies  have  a  role  to  play.  For  this  reason,  Member 
States  should  use  a  bonus/  penalty  in  their  support  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  purposes  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  problems  that  need  to  be  tackled,  such  as 
deforestation, have a much broader 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  criteria  has  to  also  consider  the  administrative 
burden to actors in the EU which, 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. This impact assessment suggests that bio-energy 
producers below 1MW capacity should be considered small-scale and should not be covered 
by  sustainability  criteria.  Some  Member  States  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  and  a  uniform  approach  across  the  EU  may  be 
difficult to achieve.  

EN 

52 

   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  existing  instruments  in  the 
environmental,  forestry,  waste  and  agricultural  policies  both  at  EU  and  national  level.  This 
would suggest that binding criteria for the use of solid and gaseous biomass specifically for 
energy purposes should not be proposed at this stage, and the 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  recommended  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 developed in a way to prevent any 
disruption to the internal market. This factor may play a part in future assessment of the need 
for Union legislation on the issues considered in this impact assessment. 

Future reflections by the Commission on the need for Union action will also be able to take 
into account Member States' national renewable energy action plans, required 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  States'  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 whether Community action may be necessary. 

In summary, it is proposed to present recommendations for sustainability criteria for solid and 
gaseous biomass used for electricity and heating purposes, allowing Member States which are 
concerned  about  unsustainable  uses,  to  put  in  place  approaches  that  are  consistent  with  the 
RES  Directive.  The  Commission  would  encourage  such  Member  States  to  work  together  to 
develop common approaches.  

It  has  to  be  pointed  out  however,  that  such  an  approach  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  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 impoverishment of agricultural soils, or higher GHG 
emissions. Reporting and monitoring systems are available in particular at EU level, but will 
need  to  be  strengthened  for  more  accurate  results.  Monitoring  requirements  under  the 
Renewable Energy Directive include the monitoring 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. 

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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  about  forest  management  will  need  to  be 
strengthened, including at national level, in the current context. 

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ANNEX I – Biomass primary potentials and fuel price for various fractions of biomass 
in the EU (EMPLOY-RES)17 

Solid biomass 

Potentials (in terms of primary energy) 

AP1 - rape & sunflower 

AP2 - maize, wheat (corn) 

AP3 - maize, wheat (whole plant) 

AP4 - SRC willow.. 

AP5 - miscanthus 

AP6 - switch grass 

AP7 - sweet sorghum 

AR1 - straw 

AR2 - other agricultural residues 
FP1 - forestry products (current 
use (wood chips, log wood)) 
FP2 - forestry products 
(complementary fellings 
(moderate)) 
FP3 - forestry products 
(complementary fellings 
(expensive)) 

2005 

76,617 

144,087 

0 

19,860 

18,246 

31,365 

14,633 

2020 

GWh 

81,235 

179,996 

207,593 

74,076 

62,943 

130,318 

43,490 

193,610 

315,416 

20,452 

33,302 

569,356 

569,356 

40,735 

96,556 

61,102 

144,834 

2005 

Mtoe 

6.6 

12.4 

0.0 

1.7 

1.6 

2.7 

1.3 

16.6 

1.8 

49.0 

3.5 

5.3 

Fuel cost (weighted 
average) 

2005 

2020 

€/MWh-p  

€/MWh-p  

36.8 

27.3 

0.0 

21.0 

19.4 

16.3 

40.9 

12.4 

12.7 

18.6 

54.3 

40.3 

41.2 

35.5 

37.1 

33.2 

60.7 

17.9 

18.3 

24.4 

2020 

Mtoe 

7.0 

15.5 

17.8 

6.4 

5.4 

11.2 

3.7 

27.1 

2.9 

49.0 

8.3 

21.0 

27.6 

12.5 

28.4 

37.3 

FR1 - black liquor 

119,396 

138,566 

10.3 

11.9 

FR2 - forestry residues (current 
use) 
FR3 - forestry residues 
(additional) 
FR4 - demolition wood, industrial 
residues 
FR5 - additional wood processing 
residues (sawmill, bark) 
FR6 - forestry imports from 
abroad 
BW1 - biodegradable fraction of 
municipal waste 

Agricultural products 

Agricultural residues 

Forestry products 

Forestry residues 

Biodegradable waste 

Forestry imports 

98,024 

98,024 

22,169 

25,857 

83,516 

97,195 

48,679 

56,508 

29,740 

101,429 

8.4 

1.9 

7.2 

4.2 

2.6 

8.4 

2.2 

8.4 

4.9 

8.7 

149,056 

207,815 

12.8 

17.9 

304,809 

214,061 

779,650 

348,718 

671,192 

371,784 

149,056 

29,740 

810,746 

416,150 

207,815 

101,429 

26.2 

18.4 

57.7 

32.0 

12.8 

2.6 

67.0 

30.0 

69.7 

35.8 

17.9 

8.7 

Solid biomass - TOTAL 

1,740,644 

2,664,508 

149.7 

229.1 

6.1 

7.2 

8.0 

9.4 

12.9 

16.9 

5.6 

6.7 

16.6 

-3.7 

28.3 

12.4 

19.6 

6.7 

-3.7 

16.6 

15.5 

7.1 

8.6 

25.5 

-4.7 

41.3 

17.9 

27.1 

8.8 

-4.7 

25.5 

24.6 

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ANNEX II – Overview of typical energy conversion efficiency of biomass plants 
(EMPLOY-RES)17 

RES-E  

Plant specification 

Efficiency 

Efficiency 

Typical 

(electricity) [1] 

(heat) 

plant size 

Biogas 

Agricultural  biogas 
plant  

28 – 34% 

[1] 

[MWel] 

0.1 - 0.5 

27 – 33% 

55 – 59% 

0.1 - 0.5 

Agricultural  biogas 
plant - 

CHP  

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 

Sewage  gas  plant  - 
CHP  

26 – 30% 

54 – 58% 

0.1 - 0.6 

Biomass 

Biomass plant  

26 – 30% 

1 - 25 

Cofiring 

37% 

Biomass  plant 
CHP  

- 

22 – 27% 

63 – 66% 

1 - 25 

Cofiring - CHP 

20% 

60% 

Biowaste  

Waste 
plant  

incineration 

18 – 22% 

2 - 50 

Waste 

incineration  14 – 16% 

64 – 66% 

2 - 50 

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Biomass 
district 
heating 

plant - CHP 

Large-scale unit  

Biomass - Medium-
scale unit  

District  heat  Small-
scale unit 

89% 

87% 

85% 

10 

5 

0.5 - 1 

Biomass - 

log wood  

75 - 85% 

0.015 - 0.04 

residential 

wood chips  

78 - 85% 

0.02 - 0.3 

heat pellets 

85 - 90% 

0.01 - 0.25 

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ANNEX III– Analysis of actions undertaken to ensure sustainable production and 
consumption of biomass in different sectors 

In the last quarter century a growing body of scientific research has revealed that the world’s 
forests are under stress (BTG report, 2008). Voluntary measures 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 indicate that there is a considerable potential to increase the use 
of forest products without harming the forest environment (e.g. EEA, 2006)62. However, it is 
accepted that there might be the risk that current voluntary initiatives (including certification 
schemes) do not cover all aspects arising from intensified 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  by,  among  others,  Criteria  and  Indicators  for 
SFM (C&I) and the Pan-European Operational Level 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  apply  SFM  principles  and 
practices.  The  United  Nations  Forum  on  Forests  agreed  in  2007  a  "Non-legally  binding 
instrument on all types of forests", whose purpose is to strengthen political commitment and 
action at all levels to implement effectively sustainable 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  worldwide  through  sustainable  forest 
management,  including  protection,  restoration,  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 protected 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  development  assistance  for  sustainable  forest 
management and mobilize significantly increased, new and additional financial 
resources  from  all  sources  for  the  implementation  of  sustainable  forest 
management. 

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There appears to be growing international consensus 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 initiatives to put in place criteria and indicators to 
monitor these developments82 have seen great variations. The Centre for International forestry 
Research  (CIFOR)  and  the  African  Timber  Organisation  do  not  use  the  same  criteria  for 
evaluating the sustainable management of forest. The criterion referring 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 Indicators for Sustainable Forest Management, and 
the  Pan-European  Forest  Process  on  Criteria  and  Indicators  for  Sustainable  Forest 
Management.  

Even  within  one  regional  initiative,  the  national  implementation  of  agreed  principles  varies 
widely. The Pan-European Operational Level Guidelines for Sustainable Forest Management, 
endorsed by the Lisbon Ministerial Conference on the Protection of Forests in Europe in June 
1998 and improved by the MCPFE expert 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 (such as maintenance and enhancement 
of forest area, forest per capita, maintenance of age structure and / or diameter 
distribution and carbon stock) 

–  Maintenance  of  Forest  Ecosystem  Health  and  Vitality  (such  as  control  of 

deposition of air pollutants, maintenance of soil conditions)  

–  Maintenance  and  Encouragement  of  Productive  Functions  of  Forests  -  Wood 
and  Non-Wood  (such  as  balance  between  net  annual  increment  and  annual 
felling of wood, quantity of marketed roundwood and non-wood goods) 

–  Maintenance,  Conservation  and  Appropriate  Enhancement  of  Biological 
Diversity  in  Forest  Ecosystems  (such  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  Enhancement  of  Protective  Functions  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 and existence of occupational safety and 

81 

82 

Extent of forest cover, Biological diversity, Forest health and vitality, Productive functions and forest 
resources,  Socio-economic  functions,  Legal,  policy  and  institutional  framework,  Water  and  soil 
protection (protective functions) 
ITTO, Montreal Process, Regional initiative for the 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 

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health requirements and accessibility for recreation and maintenance of cultural 
and spiritual values 

As  these  principles  are  insufficiently  precise  to  serve  as  clear  obligations,  their  application 
varies  from  region  to  region.  The  MCPFE  is  currently  discussing  possible  options  for  a 
legally  binding  agreement  on  forests  in  the  pan-European  region,  to  strengthen  the 
instruments to deal with new challenges for forestry, including for climate change mitigation.  

As  inter-governmental  responses  have  been  strongly  criticised  and  voluntary  certification 
schemes  started  to  develop.  There  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 

million ha

illi

h

350

300

250

200

150

100

50

0

94

95

96

97

98

99

00

01

02

03

04

05

06

07
(June)

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  Certification  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  Montreal  Principles  for  other  temperate  and  boreal 
forests, and the ATO/ITTO principles for tropical forests). 

Table 10: Certified forest area by scheme 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 
84 

ITTO (2008) "Comparability and acceptance of forest certification systems" 
Source: http://www.forestrycertification.info/ 

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PEFC  128.3 

2.3 

57.4 

5.7 

Othera  11.0 

4.8 

Total 

166.6 

11.9 

87.0 

6.4 

7.0 

193.7

17.0 

12.3 

294.9

1.2 

3.7 

a  Other  in  North  America  refers  to  American  Tree  Farm  System,  in  Asia  refers  to  the 
Malaysian Timber Certification Council, in Africa refers to areas in Gabon recognised under 
the Dutch Keurhout system 

In  2005,  the  total  amount  of  forests  worldwide  was  just  under  4  billion  hectares,  equal  to 
about 30 percent of the land area on Earth (FAO, 2005). This shows that only around 7% of 
all  forests  are  certified  in  the  world.  The  two  charts  below  show  that  certification  is 
increasing, but mostly in North America and Western 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 scheme and region in December 2006 (global) 

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The third chart shows that almost 60% of Western European forests are certified.  

Chart 3: Certified forest 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  total  EU  area.  It  is  calculated  that  annually  the  standing 
growing  stock  volume  of  wood  in  the  EU  forests  grows  by  approximately  670  million  m3. 
Around 450 million m3 of this wood every year is used for both industrial purposes as well as 
energy  or  other  household  needs.  Roughly  around  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  the  EU  Member  States.  The  highest  share  of 

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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 Renewable Energy Directive are mainly focused on 
agricultural  biomass  in  the  EU,  as  biofuels  for  transport  and  bioliquids  for  heating  and 
electricity  are  mainly  produced  from  agricultural  feedstocks.  In  general  inside  the  EU, 
sustainable  agricultural  production  is  ensured  through  tenforcing  mandatory  environmental 
standards  and  "cross-compliance"  in  the  Common  Agriculture  Policy  which  links  income 
payments to farmers and the respect of those standards. In addition, common environmental 
rules (inter alia NATURA 2000, the water Framework Directive, Nitrates Directive and EU 
legislation  on  Pesticides)  apply  to  agriculture85.  This  impact  assessment  concerns  solid  and 
gaseous biomass for energy generation, and there is low likelihood of importing solid biomass 
or biogas from agriculture from third countries.  

Energy sector: 

Some Member States are already developing sustainability requirements for bio-energy. As a 
result,  energy  companies  have  developed  their  own  standards  for  complying  with  such 
requirements. The BTG 2008 study assessed certification systems of energy companies, such 
as the Essent Green Gold Label standard and Laborelec's Sustainability Certification.  

The  Green  Gold  label  uses  forestry  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  sustainable  development  program  Agenda  21 
when  no  certification  system  is  available.  In  the  GGL  Glossary86  a  certification  body  is 
defined  as  ‘a  third  party  certification  company  that  is  accredited  ISO  65  (or  equivalent)  for 
GGL  and  is  approved  by  the  GGL  foundation’.  Most  of  the  companies  selling  biomass  to 
Essent  are  using  certification  schemes  to  prove  sustainability.  The  Green  Gold  Label  is 
establishing  partnerships  with  emerging  biomass  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 CO2 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 industry or low value residues from food industry, but wood from 
short  rotation  plantations  would  also  be  accepted.  The  Laborelec  sustainability  certification 
requires  a  supplier  declaration,  international  transport  declaration,  overview  of  the  energy 
balance,  and  an  independent  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 performing verifications.  

85 

86 
87 

Note all short-rotation coppicing (SRC) is considered under agriculture, as some Member States include 
SRC in the agricultural sectors, while others in the forest sector 
GGL Glossary version 2005.2 See http://www.controlunion.com/certification/default.htm 
Ryckmans  Y,  Andre,  N  (2007)  "Novel  certification  procedure  for  the  sustainable  import  of  wood 
pellets", Laborelec 

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Developments in other Member States, such as the Biomass Environmental Assessment Tool 
(BEAT)88  calculator  in  the  UK,  or  the  Cramer  standard  in  the  Netherlands,  could  lead  to 
industry in those countries developing new standards.  

Internationally, a labelling scheme for sustainable bio-energy based on the Eugene standard89 
has developed, which requires complete FSC certification of wood energy crops, or that wood 
biomass  comes  from  sustainably  managed  forests,  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 the auditor’s work to ensure a sufficient degree of control. 

88 
89 

www.biomassenergycentre.org.uk/BEAT 
www.eugenestandard.org 

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Annex IV: Member countries of the major inter-governmental organisations and 
processes or initiatives relevant to criteria and indicators for sustainable forest 
management 

ITTO  

Montreal Process  

Regional  initiative  for  the  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  

Consumers:  
Australia,  Canada,  China,  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 

Argentina,  Australia,  Canada,  Chile,  China, 
Japan,  Republic  of  Korea,  Mexico,  New 
Zealand,  Russian  Federation,  Uruguay  and 
USA 

Bangladesh, Bhutan, China, India, Mongolia, 
Myanmar, Nepal, Sri Lanka, and Thailand 

Cameroon, 

Angola, 
Central  African 
Republic,  Congo,  Cote-d'Ivoire,  Democratic 
Republic  of  Congo,  Equatorial  Guinea, 
Gabon, Ghana, Liberia, Nigeria, Sao Tome et 
Principe and Tanzania 

IGADD 

Burkina  Faso,  Cape  Verde,  Chad,  Gambia, 
Guinea  Bissau,  Mali,  Mauritania,  Niger  and 
Senegal. 
(7):  Djibouti,  Eritrea, 
Ethiopia,  Kenya,  Somalia,  Sudan,  and 
Uganda.  SADC  (14):  Angola,  Botswana, 
Democratic  Republic  of  Congo,  Lesotho, 
Malawi,  Mauritius,  Mozambique,  Namibia, 
Swaziland, 
South  Africa, 
Seychelles, 
Tanzania, Zambia, Zimbabwe 

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Lepartique  Process  of  Central  America  on 
Criteria  and  Indicators  for  sustainable  forest 
management 

the 
The  Ministerial  Conferences 
Protection of forests in Europe, Pan-European 
Forest  Process  on  Criteria  and  indicators  for 
sustainable forest Management  

for 

Belize,  Costa  Rica,  El  Salvador,  Guatemala, 
Honduras, Nicaragua and Panama 

Albania,  Austria,  Belarus,  Belgium,  Bosnia-
Herzegovina,  Bulgaria,  Croatia,  Czech 
Republic,  Denmark,  Estonia,  European 
Community,  Finland,  France,  Georgia, 
Germany, Greece, Hungary, Iceland, Ireland, 
Italy,  Latvia,  Liechtenstein,  Lithuania, 
Luxembourg, Monaco, Netherlands, Norway, 
Portugal,  Romania,  Russian 
Poland, 
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  

CIFOR  

Afghanistan,  Algeria,  Azerbeijan,  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 

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 

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ANNEX V – GHG methodological questions 

This annex describes in more detail the choices made for the methodology. The choices are 
guided by some general principles concerning 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 still being scientifically sound 

Robust in terms  of assumptions on  a EU-wide scale, avoiding regional differences, 
and avoiding the possibility of multiple interpretations of assumptions 

Works in a policy-context i.e. helps to fulfil the objectives of the policy in question. 

The Renewable Energy Directive requires 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  fuel.  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 alternative is to calculate the GHG emissions only until 
the  production  of  the  fuel,  e.g.  biomass  pellets,  chips,  charcoal  etc,  not  reflecting  its 
conversion to electricity and heat. These two options are considered 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  section  analyses  five  different  ways  of  allocating 
between  heat  and  other  energy  carriers.  The  last  part  of  this  annex  discusses  necessary 
amendments  of  the  greenhouse  gas  methodology  as  laid  down  in  the  Renewable  Energy 
Directive, for solid and gaseous biomass used in electricity and 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 efficiency 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 % for 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 efficiency as a function of capacity is shown for 
different CHPs (based on Ecorys, 2009): 

Figure 2: Electric efficiency for different CHPs as function of power output 

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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 targets for each Member 
State  on  the  basis  of  final  energy  consumption,  this  could  be  a  natural  conclusion,  and 
principle nr.2 above favours taking 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) 

(b) 

Analysing the chain from "cradle to gate", i.e. from cultivation to fuel 

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 (alternative A or B), as indicated in Figure 3. 

Figure 3: Depiction of alternative A or B for calculating emissions from biomass 
pathways 

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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  complicated  as  both  the  efficiency  of  the  bioenergy 
process as well as that of the fossil fuel comparator 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  where the data on efficiency for this  option  would 
come from, particularly where it concerns 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. 

FFC

S

,
ba

=

−

GHG

Pa

,

Pb

,
ba
FFC

,
ba

Alternative  A  is  similar  to  existing  RES  Directive  where  it  concerns  bioliquids91.  The 
downside is that low end conversion of biomass 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 conversion efficiency and thus be more holistic 
than alternative A. However, alternative B may only incentivise higher efficiency if there is a 
bonus  for  lower  emissions,  or  if  higher  efficiency  can  raise  a  certain  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 administrative burden. Higher end use efficiency for 
small  units  might  be  obtained  more  effectively  by  labelling  or  other  measures  targeted  at 
households  and  other  small  scale  utilisations.  Alternatively,  the  methodology  may  be 
differentiated for scale, i.e. applying alternative A for small scale utilisation and alternative B 
for large scale plants above a certain threshold. 

90 

91 

Heat is not considered a co-product in the Renewable Energy Directive where it concerns biofuels and 
bioliquids. 
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. 

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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  make,  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  highly  dependent  on  local/regional  conditions,  like 
what types of fuels are available, 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 will 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  comparator  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  cluster;  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  average  or  best  practice 
technologies, and how to weight electricity vs. heat for CHP.  

Geographical scope 

The Renewable Energy Directive applies an EU wide comparator as the fossil fuels used for 
transport are traded easily through Europe. It follows the same approach for bioliquids. The 
question is whether this approach should be used in general where it concerns electricity and 
heat or whether national or regional comparators should be used or allowed. These latter seem 
however to run into undesired effects as the different 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 suitable if biomass was not trade-able across 

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regions  or  nations.  However  it  is  trade-able  and  such  measures  could  create  market 
distortions. 

Figure 5: Effects of national Fossil Fuel Comparators  

Fuel basis (alt. a) FFCH

]
l
e
u
f

J
M

/
.

q
e
2

O
C
g
[

C
F
F

140

120

100

80

60

40

20

0

1

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 for 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 [% ]

60%

50%

40%

30%

20%

10%

0%

Fossil EU27

Coal

Gas

1

France

Germany

Poland

Use  of  soybean  would  thus  lead  to  46  %  savings  in  France  and  58  %  in  Germany,  which 
might be unjustified in reality when one is looking at the actual heat-installations. While it can 
be argued that such differentiation could be justified as the fossil fuels replaced are different 
and the biomass should be used in those regions where it replaces the most GHG burdensome 

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fossil fuels, it is not possible to say that this would actually happen in practice. It can usually 
not be known what specific fossil would be replaced 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  producers  connected  to  the  grid),  where  one  can 
clearly consider a physical short-term substituting effect; this principle does not apply to the 
heat  sector,  where  systems  are  highly  diversified  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 comparator irrespective of the use (biofuels, heat, 
electricity, CHP). This would prevent that the biomass is diverted to a specific sector where 
the  fossil  fuel  comparator  is  more  favourable.  Although  that  may  actually  lead  to  higher 
greenhouse  gas  savings,  there  is  no  guarantee  that  this  will  happen  and  it  would  not 
necessarily  reach  the  objectives  of  renewable  energy  policy  in  a  more  cost-effective  way. 
Since  a  comparator  for  biofuels  is  already  well  established,  it  would  seem  this  comparator 
should  be  taken  in  such  case,  whereas  it  has  no  particular  relevance  or  relation  to  heat  or 
electricity. This would also deviate from the approach taken for bioliquids. 

The other two options are very similar 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 the Directive for bioliquids: 

Heat: 77 g CO2eq/MJfuel 

Electricity: 91 g CO2eq/MJfuel 

A separate comparator could be given for CHP as is in the Directive for bioliquids. 

CHP: 85 g CO2eq/MJfuel 

However,  when  end  conversion  efficiency  is  not  taken  into  account  the  result  is  that  CHP 
comes  with  the  current  numbers  out  worse  than  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 plant it just makes the threshold with savings of 38 
%,  but  in  a  CHP  the  savings  are  only  calculated  to  be  33  %,  and  thus  below  the  threshold. 
However,  in  reality,  the  CHP  saves  considerably  more  GHG  emissions,  because  of  much 
higher efficiency, but the incentives here encourages 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 conversion. 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 order to obtain the same amount of electricity and 
heat if it was produced in separate plants. The fossil fuel comparator (FFC) for CHP is thus 
obtained through the following formula: 

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FFCCHP = FFCe* ηe/ ηe0 + FFCh*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. 

•  FFCe and FFCh are the Fossil Fuel Comparators for electricity and heat (given as 91 and 77 

g CO2eq/MJ) 

•  ηe0 and ηh0 are reference values for the efficiencies 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  COM  decision  21/XII/2006;  reference  values  for 
separate production of electricity and heat in application of the CHP-directive (2004/8/EC). 

This example would result in the following FFC: 

CHP: 123 g CO2eq/MJ 

The  main  disadvantage  with  this  option  is  that  it  is  still  static:  it  disregards  the  different 
heat/electricity  ratios  for  individual  CHP  installations,  which  in  fact  is  a  problem  for  all 
"alternative A" solutions where the emissions are 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 conversion, 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 both for the fossil fuel comparator (FFC) and the 
actual  biomass  pathway  i.e.  what  are  downstream  emissions  of  the  biomass  fuel  when  it  is 
converted  to  final  energy  or  other  biomass  based  energy  carriers  (such  as  biofuel).  This 
implies  a  wider  assessment  of  the  allocation  between  electricity,  heat  and  eventually  other 
products.  

Figure 7: Depiction of Alternative B 

The  outcome  of  the  analysis  of  national  or  regional  FFC  under  alternative  a,  applies  to 
alternative b as well, thus is EU-wide FFC appropriate. The remaining option regards end use 
technologies and how to determine the FFC. 

Options for end-use types: 

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•  One common FFC for heat, CHP and electricity. 

•  One comparator for each main technology cluster; heat plants, electricity plants, bioenergy 

plant92 and CHP  

•  One FFC for heat and electricity respectively. 

•  One FFC for a range of possible products and energy carriers; such as biofuel, chemicals, 

electricity, heat etc.  

For  certain  options  choices  have  to  be  made  on  whether  to  choose  average  or  best  practice 
technologies, and how to weight electricity vs. heat for CHP.  

The first option disregards the  different efficiencies and utilities of technologies and energy 
carriers. The FFC for heat would be the same as for electricity although 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,  which  is  especially  relevant  for  different 
heat/electricity ratios for CHP. In such a case a CHP with only a small amount of electricity 
produced obtain the same FFC as a CHP with much 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 option is thus discarded. 

The third option reflects the alternative fossil production of heat and electricity for all heat-, 
electricity-,  and  CHP-technologies  with  different  heat/electricity  ratios,  and  integrates  the 
difference  between  electricity  and  heat  in  a  realistic  manner  in  contrary  to  the  two  first 
options. The fourth option builds on the third option, but includes also biomass products other 
than heat and  electricity. Under this option the  FFCs  would  represent  their  fossil  substitute, 
including for chemicals and process-industry feed stocks. The FFCs of the latter two would be 
as a function of the carbon content of their fossil substitutes. Possible problems could occur 
from bio-chemicals that can have a range of utilisation, 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  introduction  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  different  technologies,  one  has  to 
decide  the  weighting  between  different  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 

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V.3 

Biomass end conversion, alternative B: Allocation between co-products for heat 
and other energy carriers  

The discussion concerning which way to attribute upstream emissions to end products in case 
of combined heat and power (CHP) is best shown with an example. The basic question is how 
the  up-stream  emissions  should  be  divided  between  the  end  products.  Since  e.g.  electricity 
and heat have different utilisation possibilities and costs, it is not obvious that a simple energy 
allocation is sufficient. The alternatives analysed are:  

– 

– 

– 

– 

Exergy allocation 

Energy allocation 

Economic allocation 

Alternative production allocation 

Finally,  a  fifth  method  for  accounting  for  emissions  between  different  co-products  (the 
"energy allocation with common indicator") is analysed 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 (heat to electricity ration of 2). The 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 electricity and 0.6 MJ of heat. 

Figure 8: Emissions from soybean in cogeneration dependent on method of allocation of 
emissions between heat and electricity 

Final energy basis

]
J
M

/

.

q
e
-
2
O
C
g
[

s
n
o
i
s
s
i
m
e
G
H
G

90

80

70

60

50

40

30

20

10

0

Exergy allocation

Energy allocation

Electricity

Heat

Economic
allocation

Alternative
production

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The exergy allocation is assuming ambient temperature of 0 °C, and heat delivered at 120 °C. 
This assumption is further discussed below. The electricity is assumed to have 100 % exergy. 
It is clear that the higher exergy 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;  

=η

T −
h

T

env

T
h

Where T is measured in absolute temperature (Kelvin), and Th is the temperature of the heat 
and  Tenv  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 delivered 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 shows the same pattern as 
exergy  and  economic  allocation,  but  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  allocates  the  emissions  solely  regarding  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, except energy allocation, hold the electricity more 
responsible for the emissions, than the heat. When 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  the  FFC  of  heat  and  electricity  balances  the  GHG-savings  results 
compared to the emission intensity as shown above. 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  

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Final energy basis

]

%

[

i

s
g
n
v
a
s
G
H
G

100%

80%

60%

40%

20%

0%

Exergy allocation Energy allocation

Electricity

Heat

Economic
allocation

Alternative
production

The resulting savings show a rather wide spread, as function of allocation method, but with 
values in the same range for all allocation methods except energy allocation, with Exergy and 
Economic allocation showing very similar results. One of the determining factors for which 
allocation  method  to  apply  is  how  the  allocation  method  is  valuing  different  heat/electricity 
ratios, and what kinds of "border-effects" to expect when the assumptions are more extreme. 
Figure  10  below  compares  the  CHP  from  the  example  above  (total  efficiency  of  90  %  and 
heat/electricity ratio of 2) with a CHP with total 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 plants with different efficiencies for heat 
and electricity conversion  

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Final energy basis

Electricity (r=2)

Heat (r=2)

Electricity (r=17)

Heat (r=17)

]

%

[

s
g
n
i
v
a
s
G
H
G

100%

80%

60%

40%

20%

0%

Exergy allocation Energy allocation

Economic
allocation

Alternative
production

It is evident how the change in heat/electricity ratio (r), changes the GHG-savings downwards 
for all allocation methods except for energy allocation 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  from  a  soybean  fed  CHP 
with  higher  fraction  of  electricity  production.  Interesting  is  also  the  high  savings  obtained 
from  electricity  in  the  case  of  high  production  of  heat  (85%)  for  "alternative  production" 
allocation.  This  stems  from  the  methodology,  which  is  not  suitable  for  CHP  solutions  with 
rather low fraction of electricity 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 light into the issue of allocation methodology is the valuation of 
heat temperature. Economic allocation would manage to account for this, but with difficulties 
finding data, as there are no disaggregated heat markets for different temperatures, and would 
thus practically lead to rather arbitrary allocation numbers. Energy allocation does not make 
any difference between 1 MJ at 10 °C or 1 MJ at 1000 °C, nor does the alternative allocation 
method. The heat temperature is an important parameter, as it determines the amount of heat 
that is possible to convert to work. Heat of higher temperature has a higher utility, as the heat 
can be converted to other forms of energy than thermal energy (namely work). However, this 
conversion is limited by the carnot efficiency, mentioned above, and repeated here: 

=η

T −
h

T

env

T
h

Where T is measured in absolute temperature (Kelvin), and Th is the temperature of the heat 
and  Tenv  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 

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utility  of  heat,  and  thus  useful  as  an  instrument  to  differentiate  between  heat  of  different 
temperature. For the purpose of calculating the carnot efficiency, it is assumed that 0 °C, or 
273 Kelvin, is the ambient temperature throughout EU, in order to keep the simplicity.  

For heat of temperature lower than 150 °C it is assumed a constant carnot efficiency equal to 
that  of  150  °C  or  423  Kelvin  (approximately  0.35).  This  is  on  order  to  avoid  very  low 
allocation  values  and  confusion  within  the  district  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 level, and gives and additional argument for keeping 
a constant Carnot efficiency for this heat market. A price difference of 1/3 is very similar to 
the Carnot efficiency of heat delivered at 150 °C (approximately 0.35). For the heat of higher 
temperatures  there  are  few  statistics  on  prices,  as  mentioned,  so  the  Carnot  efficiency  is 
applied directly as allocation factor. The proposed correlation factors are shown in figure 11, 
together with the Carnot efficiency for the whole temperature range. 

Figure 11: Correlation factors for Carnot efficiency for the whole temperature range  

y
c
n
e

i

c

i
f
f
e

t
o
n
r
a
C

1,00

0,80

0,60

0,40

0,20

0,00

Carnot efficiency

Heat temperature allocation factors

0

250

500

750

1000 1250 1500 1750 2000

Heat T (Celsius)

Applying  this  method  of  allocation  introduces  an  important  aspect  of  energy  efficiency,  as 
more  efficient  use  of  the  energy  sources  is  incentivised  through  a  realistic  representation  of 
the  different  utility  of  heat  at  different  temperature.  This  is  especially  relevant  for  high 
temperature heat demands in the industrial sector, where heat delivery at higher temperature 
often comes at the cost of lower overall energy efficiency. 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 heat, where the latter often can 
be done with higher overall energy efficiency, although with lower exergetic efficiency. The 
consequence  of  the  proposed  allocation  is  more  GHG  emissions  attributed  to  higher 
temperature heat, and thus less to the co-generated electricity. A CHP delivering final heat at 
200 °C (with energy efficiency of 0.5) would have the same GHG intensity of its electricity 

EN 

79 

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(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  another  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. The 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 the electricity produced, 
but the more electricity produced, the more savings, as the FFC for electricity is considerably 
larger than for heat. The basis of the methodology thus becomes a question of what products 
that are replaced and what savings this brings. For a CHP the FFC is given by: 

FFCCHP = FFCe* ηe/(ηe + ηh) + FFCh*ηh/(ηe + ηh) 

For  different  heat  and  electricity  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  comparison  is  also  the  heat-  and  electricity-only 
plants shown as function of their 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 function of GHG savings (based on palm 
oil) 

]

%

[
s
g
n
i
v
a
s
G
H
G

80%

60%

40%

20%

0%

-20%

-40%

-60%

Heat and electricity efficiency

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

0,35

CHP

Electricity-only

Heat-only

EN 

80 

   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 same figure applied to waste wood as source 
gives the same pattern, but at much higher savings, as shown in Figure 13. 

Figure 13: Heat and electricity efficiencies as a function of GHG savings (based on waste 
wood) 

]

%

[

s
g
n
i
v
a
s
G
H
G

100%

95%

90%

85%

80%

CHP

Electricity-only

Heat-only

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

0,55

Heat and electricity efficiency

Note that the numbers for CHP ends at 0.5 and 0.35 as this is assumed to be the maximum 
power to heat ratio with still a total efficiency of 85 % (assuming that higher efficiency for 
electricity requires a lower back-pressure, and thus less recoverable heat). 

This  method  of  weighted  FFC  applied  to  the  examples  given  further  up  is  summed  up  here 
(the soy CHP and third generation 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 only 5 % electricity efficiency is assumed (same total efficiency 
of 90 %). This shows how the weighted FFC method incorporates the strength of economic-, 
exergy- and alternative production allocation without being equally complicated. With energy 
allocation no credit is given for higher portion electricity produced, as one recalls from Figure 
13. The third generation plant that produces electricity, heat and 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 fi and each product i has a FFC of FFCi: 

FFC

−

S

=

GHG
FFC

emissions

Where: 

∑ ⋅
f

i FFC
i

n

i

FFC

=

EN 

81 

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With  EU27  average  and  assumed  efficiencies  as  in  the  CHP  directive,  the  FFCi  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 different 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, but  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  service,  or  at  the  system 
boundary  of  the  CHP?  The  conclusion  here  is  the  term  "final  energy"  as  defined  in  the 
Renewable Energy Directive (Directve/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  differentiated  economic  valuation  of  heat  at  varying 
temperature. 

Economic  allocation  has  its  disadvantages  related  to  the  changing  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  well,  and  shows  similar  allocation  pattern  as 
economic  and  exergy  allocation.  The  main  disadvantage  is  the  need  for  determining 
"alternative efficiencies", and especially in the case of more complex bio plants (refineries) It 
has also been shown that it is not suitable for not so common CHP configurations, with e.g. 
very low electricity efficiency. The alternative allocation method is thus discarded. 

In  order  to  avoid  having  different  saving  numbers  for  different  products  coming  from  one 
production  facility,  it  is  desirable  to  obtain  one  figure  for  all  the  products.  All  the  options 
above result in one figure for the heat and another figure for the electricity coming from the 
CHP.  The  fifth  alternative  (energy  allocation  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 for 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 and drinks, it would be illogical to have a fossil 
fuel comparator as in integral part of determining the GHG emissions, this would be in breach 
with the second principle for a sound methodology. This option is thus discarded. 

Conclusion 

For simplicity and coherence with the Renewable Energy Directive, energy allocation is kept 
for all allocation issues, except where heat is co-produced with other energy commodities. In 

EN 

82 

   EN 

 
such  a  case;  other  energy  commodities  are  given  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 the methodology is presented in section V.4. 

V.4 Equations describing the methodology 

Greenhouse  gas  emissions  from  the  production  of  solid  and  gaseous  biomass  fuels,  before 
conversion into electricity and/ or heating and cooling, shall be calculated as: 

E = eec + el + ep + etd + eu - esca– eccs - eccr, 

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 capture and geological storage, and; 

eccr = emission savings from carbon capture and replacement. 

Emissions from the manufacture of machinery and 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  conversion  to  electricity  and/  or  heat  or 
cooling produced shall be calculated as follows: 

For energy installations delivering only useful heat: 

EC

h

=

E
η
el

For energy installations delivering only electricity: 

EC

el

=

E
η
h

For energy installations delivering only useful cooling: 

EN 

83 

   EN 

 
 
 
EC

c

=

E
η
c

Where: 

EChl  = 
heating. 

ECel  = 
electricity. 

= 

ECc 
cooling 

Total  greenhouse  gas  emissions  from  the  final  energy  commodity,  that  is 

Total  greenhouse  gas  emissions  from  the  final  energy  commodity,  that  is 

Total  greenhouse  gas  emissions  from  the  final  energy  commodity,  that  is 

= 

ηel 
the annual fuel input. 

The electrical efficiency, defined as the annual electricity produced divided by 

= 

ηh 
The  thermal  efficiency,  defined  as  the  annual  useful  heat  output,  that  is  heat 
generated to satisfy an economically justifiable demand for heat, divided 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 otherwise be satisfied at market conditions. 

For the electricity coming from energy installations delivering useful heat: 

EC

el

=

E
η
el

⎛
⎜⎜
⎝

C

el

C
η
⋅
el

η
⋅
el
el
C
+

η
⋅
h

h

⎞
⎟⎟
⎠

For the useful heat coming from energy installations delivering electricity: 

EC

h

=

E
η
h

⎛
⎜⎜
⎝

C

el

C
η
⋅
el

η
⋅
h
h
C
+

η
⋅
h

h

⎞
⎟⎟
⎠

Where: 

= 

Cel 
set to 100 % (Cel = 1). 

Fraction of exergy in the electricity, or any other energy carrier other than heat, 

Ch 

= 

Carnot efficiency (fraction of exergy in the useful heat).  

Carnot efficiency, Ch, for useful heat at different temperatures: 

C

h

=

T
h

T
0−
T
h

EN 

84 

   EN 

 
 
 
 
 
Where: 

= 

Th 
point of delivery as final energy 

Temperature,  measured  in  absolute  temperature  (kelvin)  of  the  useful  heat  at 

T0 

= 

Temperature of surroundings, set at 273 kelvin (equal to 0 °C) 

For Th < 150 °C (423 kelvin), Ch 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 upstream in the production pathway  

Co-products encountered in the production of electricity and heating are different than the co-
products in biofuels for transport, where an 'allocation method' based on energy content was 
chosen.  In  the  case  of  electricity  or  heat  production,  the  co-products  do  not  always  have 
energy  content.  Possible  co-products  include:  digestates  produced  from  biogas  production 
(which  can  be  used  as  fertiliser),  ash,  flue-gas  (cleaning  products)  or  surplus  heat  from 
combustion, char and gas as co-products of pyrolysis, compost as a sub-product of producing 
woodchips from gardening residues as well as nutriceuticals, fabric such as animal hides and 
pharmaceuticals,  materials  from  the  processing  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  and  substitution),  still  apply.  The  substitution 
method  brings  substantial  uncertainties  (Ecorys  200793),  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 difficulties regarding which 
prices to apply. Should one apply prices before tax; because it is the market value, or after tax; 
since  the  tax  supposedly  represents  external  costs.  Further;  how  to  deal  with  prices  of 
products  that  are  subsidised  upstream  in  the  production  chain?  Exergy  allocation  leads  to 
methodological  uncertainties,  since  the  definition  and  widespread  use  of  "lower  heating 
value" does not have a counter-part within exergy, and many processes would be difficult to 
assess  on  an  exergy  basis.  Exergy  (2.  law  of  thermodynamics)  is  defined  as  the  sum  of 
"internal  energy",  "available  PV  work",  "entropic  loss"  or  "heat  loss"  and  the  final  term 
"available  chemical  energy".  To  establish  these  terms  for  different  pathways  would  be  a 
methodological  challenge.  Energy allocation  is thus used.  This conclusion also  bears on the 
arguments presented in Annex 7, part F of the impact 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  emissions)  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 and by-products. This is discussed in the following 
section. 

93 

Ecofys (2007) "Towards a harmonised sustainable biomass certification scheme" 

EN 

85 

   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 stakeholders 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 occurs instead of providing single values in the 
legislation. This is because single value data cannot 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 diverse range of soils (organic – inorganic soil). 
Respondents  to  the  public  consultation  also  argued  that  carbon  stock  figures  should  take 
account  of  tropical  and  temperate  climatic  conditions.  Guidance  will  be  provided  in  the 
Communication on practical guidance for implementing the biofuels/ bioliquids sustainability 
scheme (due in the first quarter of 2010). In this impact assessment, it is assumed that single 
reasons.
values 

appropriate 

same 

not 

the 

are 

for 

EN 

86 

   EN 

 
ANNEX VI – Costs to economic operators associated with efficiency measures (ECORYS, 2009) 

Type of 
measure 

Indicator  
BTC 

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/savi
(GW)

Low 

High 

Large-scale 
power  and 
CHP 

Heat delivery 

Use of larger part of 
the heat 

50,000,000

200,000,00
0

Euro per 
installation 

Add on 

Flue gas condenser 

1,000,000

1,000,000 Euro/MW 

Heat delivery 

Use heat, existing 
installations 

50,000,000

200,000,00
0

Euro per 
installation 

Co-firing  

Heat delivery 

Use heat, new 
installations 
Use heat, existing 
installations 
Use heat, new 
installations 

50,000,000

50,000,000

50,000,000

200,000,00
0
200,000,00
0
200,000,00
0

Euro per 
installation 
Euro per 
installation 
Euro per 
installation 

Improvements, 
existing installations 

Improvements, new 
installations 

10,000

12,000 Euro/kW 

6,000

10,000 Euro/kW 

Flue gas condenser 

1,000,000

Use heat 

2,000,000

1,000,000 Euro/MW 
Euro per 
installation 

10,000,000

Heat delivery 

Heat delivery 
Electrical 
efficiency 
improvement 
Electrical 
efficiency 
improvement 

Add on 
External heat 
delivery 

Add on 

ORC on an average 
700 kW digester 

400,000

Euro per 
installation 

0

Lo
w 
33
% 
8
% 

30
% 

28
% 
35
% 
30
% 

1
% 

6
% 
8
% 
20
% 

8
% 

High  Low

High 

Low 

High 

Low  H

65% 

24 

10% 

24 

24 

24 

60% 

1.1 

1.1 

55% 

4.8 

9.5 

70% 

2.2 

2.2 

60% 

1.6 

1.6 

2% 

2.2 

2.2 

GW 
biomass 
GW 
biomass 
Gwelectric 
-> only 
biomass 
Gwelectric 
-> only 
biomass 
GW electric 
green 
GW electric 
green 

GW electric 
green 

15% 

60% 

1 

20% 

60% 

<1 

4988 

5% 

15% 

<1 

37335 

14008 

9710 

20% 

40% 

1 

10% 

20% 

20% 

40% 

<1 

<1 

14008 

20% 

50% 

<1 

10% 

1.6 

1.6 

GW electric 
green 

9710 

60% 

90% 

10% 

12 

12 

GW thermal

42210 

20% 

60% 

<1 

<1 

35% 

2.0 

1.9 

GW thermal

10,771  

10% 

50% 

<1 

15% 

1.7 

1.9 

GW electric  10,771 

50% 

90% 

<1 

87 

EN 

Waste 
incineratio
n 
District 
heating 

Manure 
(co-) 
digestion 

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 case of intermediate processing (e.g. briquetting, 
pelletising, chipping) 

For raw materials coming from tropical countries (Brazil, Indonesia, Thailand), transportation to the processing site is assumed to be by 
truck,  50  km,  and  transport  to  the  export  terminal,  700km,  while  transport  to  the  EU  vary  for  Brazil  (by  ship,  10186  km,  and  for 
Indonesia by ship, 13000 km and for Thailand by ship 12500 km). 

EN 

88 

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Biofuel production pathway 

Typical  
GHG emitted (g CO2eq/MJ) 

Default 
GHG emitted (g CO2eq/MJ) 

Total 

Cultivation 

Processing 

Wood chips from forest residues (EU forest) 
Wood chips from forest residues (Brazilian forest) 
Wood chips from short rotation forestry (EU forest) 
Wood chips short rotation forestry (eucalyptus) 
Wood briquettes or pellets from forest residues (EU forest) – wood 
as process fuel 
Wood briquettes or pellets from forest residues (EU forest) – NG as 
process fuel 
Wood briquettes or pellets from forest residues (Brazilian forest) -
wood as process fuel 
Wood briquettes or pellets from forest residues (Brazilian forest) - 
NG as process fuel 
Wood briquettes or pellets from short rotation forestry (EU) - wood 
as process fuel 
Wood briquettes or pellets from short rotation forestry (EU) - NG as 
process fuel 
Wood briquettes or pellets from short rotation forestry (eucalyptus) - 
wood as process fuel 
Wood briquettes or pellets from short rotation forestry (eucalyptus) - 
NG as process fuel 

Charcoal from forest residues (EU) 
Charcoal from residues (Brazilian forest) 
Charcoal from short rotation forestry (EU)  
Charcoal from short rotation forestry (Eucalyptus) 

wheat straw (EU) 
Bagasse briquettes – (Brazil) wood as process fuel 
Bagasse briquettes – (Brazil) NG as process fuel 
Bagasse bales (Brazil) 
Palm kernel (Indonesia) 

Rice husk briquettes (Thailand) 
Mischanthus bales (temperate continental climate) 
biogas from wet manure  
biogas from dry manure  

Cultivation  Processi

0.0 
0.0 
2.0 
2.9 
0.0 

0.0 

0.0 

0.0 

2.1 

2.1 

3.6 

3.6 

0.0 
0.0 
4.1 
5.9 

0.0 
0.0 
0.0 
0.0 
0.0 

0.0 
3.6 
0.0 
0.0 

ng 
0.4 
0.4 
0.4 
0.4 
0.5 

15.4 

0.5 

15.4 

0.5 

15.4 

0.5 

15.4 

32.8 
32.9 
32.9 
33.0 

0.8 
0.0 
15.0 
0.8 
0.0 

0.0 
1.1 
5.0 
5.0 

EN 

Biogas from wheat and straw (wheat whole plant) 
Biogas from maize as whole plant (maize as main crop) 
Biogas from maize as whole plant (maize as main crop) – organic 
agriculture 

16.9 

89 

0.0 

14.3
10.7

5.0 
5.0 

Transport & 
distribution 
0.3 
20.0 
0.3 
20.0 
0.7 

0.9 

13.7 

13.7 

0.7 

0.6 

13.7 

13.7 

0.7 
8.0 
0.7 
8.0 

0.3 
13.5 
13.5 
15.8 
21.8 

23.3 
0.3 
1.6 
0.5 

0.3 

1 
21 
3 
24 
2 

17 

15 

30 

4 

19 

18 

33 

34 
41 
38 
47 

2 
14 
29 
17 
22 

24 
6 
7 
6 

0.0 
0.0 
2.5 
3.5 
0.0 

0.0 

0.0 

0.0 

2.5 

2.5 

4.4 

4.4 

0.0 
0.0 
5.0 
7.0 

0.0 
0.0 
0.0 
0.0 
0.0 

0.0 
4.4 
0.0 
0.0 

18 
19.3 
16 

0.0
0.0

20.3 
17.2 
12.8 

Transport & 
distribution 
0.4 
23.9 
0.4 
23.9 
0.8 

1.1 

16.4 

16.4 

0.8 

0.7 

16.4 

16.4 

0.8 
9.6 
0.8 
9.6 

0.3 
16.2 
16.2 
18.9 
26.2 

28.0 
0.3 
1.9 
0.6 

EN 

0.3 
0.0 
0.0 

0.4 
0.4 
0.4 
0.4 
0.5 

18.4 

0.5 

18.4 

0.5 

18.4 

0.5 

18.4 

39.4 
39.5 
39.5 
39.6 

1.0 
0.0 
18.0 
1.0 
0.0 

0.0 
1.4 
6.0 
6.0 

0.0 
6.0 
6.0 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
EN 

90 

EN