RED II – forest industry not out of the woods yet
The debate in Europe on how to define sustainability criteria for forest biomass has been harsh. An unfortunate lack of knowledge in the European Parliament’s Environment Committee (ENVI) about sustainable forest management has had ENVI suggesting criteria during its negotiations that would have made it practically impossible to qualify any forest or forest-industry bioenergy as sustainable. But ENVI's adopted position also shows that the forest industry is not out of the woods yet.
According to the Swedish Forest Industries Federation (SFIF), a trade body that represents the interests of the Swedish forest industries, there are both pros and cons for the development of the bio-based economy in the 23 October position from the European Parliament’s Environment Committee (ENVI) on the revision of the Renewable Energy Directive (RED).
During its negotiations, ENVI had suggested sustainability criteria, which SFIF says, could have made it “more or less impossible” to qualify any forest or forest-industry bioenergy as sustainable.
These criteria would have been devastating for the forest industry and for Sweden and the European Union to deliver on climate goals. After lengthy negotiations, the committee, however, finally choose to respect national legislation and practice when assessing whether bioenergy from forests and forest industries is sustainable. Just like us, the committee concluded that they want to see a risk-based approach, said Helena Sjögren, Head of Bioenergy Policy at SFIF.
However, SFIF considers that ENVI’s position on the manufacturing of forest-derived advanced biofuels hinders such development by defining “unnecessary and non-justifiable” criteria. The position states, that if a feedstock from forest industry is used to produce a biofuel, that biofuel is only advanced if the producer can ensure that no other user of that same raw material is disfavoured because of the biofuel production.
This will be impossible. A company can keep track of their own customers and suppliers, but they will not be able to identify what other actors within completely different sectors are doing. I do not understand why the ENVI committee chooses to meddle in on this subject. The sustainability criteria should be about sustainability. They should not govern how renewable feedstocks are used, neither should they define what products the market should develop and produce, said Sjögren.
According to Sjögren, ENVI has elected to remove tall oil (tall oil pitch and crude tall oil – CTO), a residue from the pulp industry, from the list of eligible feedstocks for the production of advanced biofuels.
Tall oil is a residue from the pulp industry and should, of course, continue to be eligible to be used for advanced biofuels, said Helena Sjögren.
In addition, she expressed concern over that ENVI also concluded that the European Commission (EC) will have the authority to remove – not only add – raw materials from the list of eligible feedstocks.
This will increase the risk for entrepreneurs and will hamper investments in the manufacturing of advanced biofuels since feedstocks can be taken off the list simply after a decision by the European Commission, she said.
Finally, SFIF urges the European Parliament to ensure that the revision of the RED, truly supports renewable energy at the expense of fossil energy.
Tall oil an ineligible feedstock?
The move to remove tall oil from the list of eligible feedstocks, assumedly on account of being defined by ENVI as a “product” or “co-product” rather than a residue, for the production of advanced biofuels will have severe implications and serves as a good example of the consequences of ENVI’s market “meddling” as Sjögren put it.
As a biochemical, tall oil and derived components have several uses. It is found in fragrances, in household chemicals such as detergents, washing up liquids and floor cleaning agents, used as a component of adhesives, rubbers, inks as well as a binder in cement to mention a few.
However, notwithstanding these uses, a recent study on the global supply and demand of CTO concluded that the market is “not overly tight and potential surplus of about 850 000 tonnes of CTO is still available that could be tapped into”.
The report pegs the total potential CTO supply to around 2.6 million tonnes per annum whereas current actual CTO demand is approximately 1.75 million tonnes, of which about 1.4 million tonnes is used by distillers and roughly 230 000 tonnes is currently used for biofuels.
In other words, it is the annual excess of CTO, per definition a residue as it is “leftover”, that is being targetted as a feedstock for advanced biofuels. Together, the Nordic forest industry and fuel producers have invested heavily into developing processes and logistical infrastructure to convert more of this residual CTO into renewable diesel fuel.
As Sjögren remarked, ENVI’s adopted position seemingly throws the proverbial spanner in the works for Nordic forest-industry based bioenergy – perhaps lignin is next on the hit-list. Like for CTO, there are biochemical applications and, heaven forbids that ENVI realises, at least one food ingredient application.
My lips are sealed on what that fully commercialised application is for fear of lignin and, thus by default, spruce trees being classified as a food-crop.