Sustainability of Biomass

Transcription

1 Association européenne pour la Biomasse European Biomass Association Renewable Energy House 63 rue d Arlon, 1050 Brussels Phone: Fax: info@aebiom.org AEBIOM position paper September 2009 Sustainability of Biomass The European Commission will publish a report on sustainability criteria for all types of biomass, other than biofuels and bioliquids, by the end of In this paper AEBIOM explains its position on the sustainability issue for biomass and its applications for heat and electricity, below referred as Biomass. AEBIOM is in favour of a sustainable production and efficient use of biomass for energy. In Europe the sustainable production of wood in forests is warranted by the national forest legislation and its implementation by the federal and regional governments. A sustainable agricultural production is ensured by the cross compliance rules of the common agriculture policy (CAP), by different national and regional laws on soil and water protection, fertilizer use, etc. Having already this legislation and administration in place AEBIOM believes that additional mandatory certification schemes for biomass production are not necessary and could become a barrier to the rapid mobilisation of biomass for energy. AEBIOM favours voluntarily certification schemes used by big producers of biomass or by member states, especially those that rely heavily on imported biomass from abroad. This position on certification of solid biomass is based among others on the following arguments: Biomass for heat is produced by millions of stakeholders (farmers and forest owners). Given this large number of players the cost of a mandatory certification system for all users might be higher than the possible benefits. Biomass for heat and electricity is mainly used as by-product. Therefore, it makes more sense to regulate issues of sustainable production of biomass within the agricultural and forest policy rather than for by-products of the wood industry within the energy policy. Too strict rules for the certification of biomass could become a new barrier to the production of biomass and lead to a reduced supply and thus encourage the increased use of fossil fuels, which leads definitely to a more unsustainable energy system than using biomass. Certification might reduce the biomass supply, increase the biomass prices, and jeopardize the achievement of the RES objective, knowing that bioenergy accounts for 2/3 of renewables. 1

2 Table of contents 1. About sustainability About the importance of biomass for energy Do we need a specific certification scheme for biomass? The way forward the analysis Necessity to consider agriculture and forestry sectors as a whole Sustainability of by-products? Necessity to exclude small players Essential differences between biomass and biofuels Which criteria: improved efficiency, GHG reduction, transport distance, any others? Efficiency in the use of solid biomass and fossil fuels in bigger applications Imports of biomass Keep costs reasonable Conclusions and recommendations No mandatory certification system Starting with a voluntary system Clear rules for imported biomass A comprehensive study on the potential of GHG emissions reduction Respecting level playing field

3 1. About sustainability One widely accepted definition of the term sustainability was delivered by the Brundtland Commission (World Commission on Environment and Development) in 1989: "[to meet] the needs of the present without compromising the ability of future generations to meet their own needs. Wikipedia 1 defines sustainability, in general terms, as the ability to maintain balance of a certain process or state in any system. It is now most frequently used in connection with biological and human systems. In an ecological context, sustainability can be defined as the ability of an ecosystem to maintain ecological processes, functions, biodiversity and productivity into the future. Applied to agriculture and forestry we can elaborate general criteria such as: Conservation of the fertility of the soil Protection of the water quality Respect of biodiversity Maintenance of the carbon stock of the soils Annual forest harvest in a region smaller or equal to the annual production The development of biomass as energy carrier makes sense only if this biomass is produced in a sustainable manner taking into account the above mentioned criteria. Therefore, AEBIOM is in favour of a further development of bio-energy based on sustainable production and efficient use of biomass. Another obvious conclusion can be drawn from the aforementioned definitions: fossil fuels are not sustainable. Firstly, exhausting the fossil reserves on the planet compromises the ability of future generations to meet their energy needs. Secondly, reinforcing global warming endangers future living conditions on earth. Thus, the most important step towards a more sustainable energy system would be a rapid reduction in the use of fossil fuels. 2. About the importance of biomass for energy Bioenergy will play a major role to solve the global climate threat, and, for Europe, to meet the renewable energy target. Bioenergy has the potential to be the major energy source in many European countries and regions already in the short term. Bioenergy systems can be applied in every country and region, the technologies are readily available and production of biomass for energy can largely be taken care of by existing players in agriculture and forestry. This will generate employment and income in the rural areas and regions throughout Europe, and will be an integrated part of better land and forest management. Most supply chains using biomass for energy have a very good energy balance and green house gas reduction. The energy input to harvest and transport to the heat 1 Regional Ecosystem Office (U.S), REO Information Center Definitions. Northwest Forest Plan (NWFP). Definition of ecological sustainability. fromwikipedia 3

4 plant is typically less than a few percent. A modern combined heat and power plant has an efficiency of more than 90 percent. Besides reducing greenhouse gas emissions this development will greatly contribute to a more secure energy system. The development of a modern bioenergy sector is still in its early stages in most countries. Thus the national policy in favour of bioenergy will play a crucial role in order to better use the biomass potential of bioenergy and to achieve the targets of the Directive on Renewables. 3. Do we need a specific certification scheme for biomass? In order to answer this question we should evaluate the advantages and drawbacks of a possible certification scheme. In other words: What problems could be addressed by such a scheme and what problems might arise? What advantages could a sustainability scheme provide? A sustainability scheme guarantees to the final consumers that bio-energy developers take care about sustainability. Independent schemes would also help companies to better justify their high level corporate governance standards. Greenhouse gas reduction is one major advantage of bio-energy and so far the GHG-criteria is not considered in any wide certification scheme for solid biomass (while now it is the case for biofuels). Certification would reinforce this argument in favour of bioenergy. A certification system would also include imports of biomass and would thus promote sustainable agriculture and forestry production abroad. Taking into account the EU-objectives of the RES directive and the development of large scale bio-energy projects, a scheme might prevent public criticism especially in the case of large imports of biomass. What problems could such a scheme create? There are existing mandatory sustainable management schemes for agriculture and forestry in Europe. An additional scheme on sustainability could be redundant. A certification implies extra administrative burdens/costs for farmers and forest owners whilst the benefit of the certification would go to energy producers/distributors. This could cause the farmers and forest owners to leave additional parts of their land idle and to keep the forest untouched at all. Thus, the biomass potential in Europe would not be mobilised or, even worse, the biomass use would decrease. Unfortunately such tendency is already visible with agricultural rules getting stricter and the price for agricultural commodities coming down all the time. There is no level playing field with competing fossil alternatives as they do not apply any certification scheme. Certifying biomass to energy sector would lead to unfair competition, unfair barriers to bio-energy, and a lower market share for bio-energy to the benefit of fossil fuels. Need for certification will reduce the available biomass potential for energy purposes significantly so that it will be questionable if EU targets, where bioenergy will have to cover 60% of the proposed RES share, will be feasible at all. 4

5 As certified biomass will become scarce but demand increases, its price might skyrocket setting profitability of bioenergy far back Comparing the possible advantages and the possible drawbacks it is not obvious that a generalised certification scheme would bring a positive balance between costs and benefits. Therefore, it is suggested to analyse the subject carefully before deciding among different options. 4. The way forward the analysis To better understand the complexity of the subject, different aspects of the production of biomass for heat and electricity have to be examined Necessity to consider agriculture and forestry sectors as a whole The primary production of biomass coming from agriculture and forestry serves different outlets: it provides vegetable food for humans, feed for animals that deliver various products for humans (milk, meat, eggs, etc.), raw materials for various industries (as example: starch industry, paper and pulp industry, wood industry. etc) and raw materials for the energy sector. In many cases the final use of raw materials coming from the primary sector is not clear during the time of production: the harvest of the planted corn might be sold to a pig farmer, to the starch industry, to a biogas plant or to an ethanol plant. The same applies to the wood production in forests with multiple uses like pulp, furniture industry, saw mills and bio-energy. National and European legislation in the field of agriculture and forestry as well as the agricultural and forest administration have to secure a sustainable production of biomass independently of its end use. This is already done in Europe. The national forest legislations and the forest administrations aim to warrant a sustainable forest production. In addition, voluntary certification schemes and conventions such as the Ministerial Conference for the Protection of Forests in Europe (MCPFE) and the derived voluntary schemes for forest (FSC, PEFC, etc.) exist to prove the sustainable production. As a result, forest areas and consequently the carbon stocks in forests is increasing in many European countries. And for agriculture, the cross compliance rules as a comprehensive system of recording all production steps for each farmer and the checks by national authorities and EU authorities are in place. These rules safeguard an environmental friendly sustainable agriculture. Maybe this can probably be improved in some regions. Yet, it is better to improve the existing systems than to set up a parallel administration that leads to additional costs and the effect, that biomass not fulfilling the criteria for energy might be used for food and fibre or vice versa. It is obvious that sustainable production in the primary sector can only be tackled in a meaningful way for the sector as a whole and not isolated for those segments going to the energy sector only. It is preferable to improve the existing schemes in favour of sustainability of agriculture and forestry rather than implementing new conflicting rules based on European energy policy Sustainability of by-products? 5

6 Leaving transport biofuels aside there is already a scheme in the RES Directive the following materials are mainly used for bioenergy at present: Biomass as by-product : - fire wood - chips from saw mills and wood industry - chips coming directly from the wood after thinning and clear cutting operations - chips from the landscape maintenance - other by-products of the wood business such as bark, saw dust, branches - Waste wood - black liquor not used lignin in the paper and pulp industry - refined wood such as brickets an pellets - straw - fruit biomass such as olive kernels, wood from orchards, vineyards etc. - chicken manure - manure from pigs, cattle, etc. - biological waste from households, the food industry. Biomass as main/dedicated product for energy - silage form corn, sweet sorghum, catch crops for biogas - energy grass from miscanthus, reed canary grass - chips from fast growing trees (SRC, poplars, aspen, etc.) - fire wood coming from dedicated crops At present, more than 95% of the biomass for heat and electricity comes from byproducts as listed above. This leads to the question: how will one define criteria for the sustainable production of the by-product if the same criteria does not apply for the main product? It is important to note that in the RES directive the sustainability criteria, except for the CO 2 savings, do not apply for by-products and waste (article 17.1). A simple copy-paste of the biofuels criteria to biomass would mean that most of the biomass would be exempted from any criteria except CO 2. Once again, this analysis confirms the statement that the sustainability issue concerning the production of solid biomass has to be solved within the forest and agriculture policy and not within the energy policy Necessity to exclude small players In Europe the number of forest owners producing wood is far above 10 millions and on the other hand 15 to 10 millions end users are using wood. In 2007, about 90 Mtoe of biomass, mainly wood, was used for bio-heat and bio-electricity. The quantity of biomass consumed by these end users differs widely: some of them might use 2 tons of wood per year or less, the biggest are using far more than tons of biomass per year. The following table gives an overview: Table 1: Importance of bioenergy in Europe in 2007* and number of players** biofuels excluded Type of bioenergy Primary energy Number of biomass users/ (ktoe)* bioenergy producers** Biomass used directly by to 20 millions users households and services for heat Biomass for electricity and Ca users 6

7 cogeneration Biomass used directly by industries for heat users Biomass used by district users heating plants Total *Eurostat ** AEBIOM estimation. Almost 40% of the solid biomass is used by millions of small users like forest owners using their own fire wood for their homes, family houses buying pellets for their pellets stoves or boilers, farmers using wood chips or straw etc. But it is questionable who will be responsible to prove the certification in the field of biomass. Households could be considered as bioenergy producers (and in this case they might be considered as responsible to certify their production) but also as end users (and in this case they do not have to prove anything, like a car driver using biofuels. In this case maybe the biomass retailers might be the responsible ones). About one third of the solid biomass is used for cogeneration or electricity production. In this market segment rather big users prevail. Around 20% of the biomass is used in the industry directly. These are mainly companies in the field of the paper and pulp industry, the wood and furniture industry they buy wood for their main business and use the by-products to meet their energy needs. From this it follows that a certification system for all producers/users of solid biomass would be challenging in terms of millions of actors involved Essential differences between biomass and biofuels For the first time, sustainability criteria were introduced for the biofuels sector in the Directive 2009/28/EC from This directive stipulates that to count towards the transport fuel target, the use of biofuels must save at least 35% of GHG emissions compared to fossil fuels until 2017 and 50% from 2017 (or 60% for installations built after 2017). The sustainability criteria also includes following restrictions: the biofuels should not be made from raw material obtained from land with high biodiversity value such as primary forest and other wooded land, wetlands, undrained peatlands, forest land with trees higher than 5 metres, areas designated for nature protection purposes etc. Such sustainability criteria should be applicable for both European and imported biofuels. Can these criteria on GHG, biodiversity and carbon stocks be transposed to biomass for heat and electricity in a meaningful way? GHG GHG emissions savings are already very high for heat and electricity from biomass. A threshold of 60% CO 2 reduction as compared to the fossil fuel standard is already achieved for the vast majority of projects. Yet, setting higher mandatory threshold values for bio-heat and bioelectricity compared to biofuels would lead to a discrimination of the use of biomass. Yet, a certification with the aim to certify a GHG reduction of 35% or 50% would result only in administrative burdens rather than in improvements of the systems. 7

8 An example: A rural settlement using l heating oil produces 40,5 t C0 2 just by burning the oil without calculating the emissions of the production, processing and transporting the oil to the end-user. The same settlement after switching to a wood chip boiler needs 200 m³ wood chips. The fossil fuel needed for cutting the trees in the nearby local forest, chipping them and hauling the chips to the settlement lies in the size of 150 l diesel, causing about 405 kg C0 2 emissions. That is one percent of the fossil alternative, the reduction amounts to 99%, although the emissions of the production and the transport of the chips were taken into account, which in this example is not the case for the fossil alternative. Biodiversity and carbon stocks Exploiting a badly managed forest and replanting new trees, renovating grass land or replacing grass land by perennial energy crops such as short rotation coppices should be possible. By doing so biomass production can help to better maintain the landscape, improve biodiversity, increase renewable bio-energy production and increase CO 2 savings and the carbon storage per hectare. Therefore land use change per se is not a negative development; it occurs permanently in a growing economy and it can improve the C0 2 balance as it is the case in many places in Europe where non-used agricultural land turns into forest land and thus increases the carbon storage Negative environmental and social impacts are an issue outside Europe, not in Europe. Forest area in Europe is increasing and there is no large forest clear cuts for bioenergy. For example, Sweden has a very high bioenergy share and today the stored carbon in Swedish forests is more than double compared to the 1920's. Criteria as mentioned in the RES directive under article a) (primary forest and other wooded land, namely forest and other wooded land of native species, where there is no clearly visible indication of human activity and the ecological processes are not significantly disturbed) is not relevant for biomass exploitation in Europe. In many forest areas, especially in northern regions with colder climate, it takes the trees more than 100 years to reach maturity, without any clearly visible human activity. But these are normal productive forests and owners have a legal right to exploit it to get normal income. It is a fact that large areas need to be protected by law but a generalised rule is not appropriate. Another example speaks by itself. In Sweden a lot of farmland with low productivity was planted with forest trees (spruce) in the 1960 s and 1970 s. Many of these spuce plantations today have been infested with a fungus that makes the trees rot, and they can therefore not be used for pulpwood or timber. A good alternative could be to cut down some of these forests and return to agricultural fields, and plant them with willows, reed canary grass or some other energy crop. Applying the RES directive criteria, this strategy would be impossible. Therefore, applying the scheme developed for transportation biofuels to biomass does not make sense. 8

9 4.5. Which criteria: improved efficiency, GHG reduction, transport distance, any others? Efficient conversion of biomass to final energy Biomass is a limited resource and should be used efficiently, and therefore it makes sense to improve the efficiency in the use of biomass, were it is possible. Solid biomass for heat is used in millions of small and medium sized boilers. It makes sense to improve the efficiency of the boilers offered on the markets and to replace inefficient old boilers. The RES directive mentions a minimum efficiency as follows in article 13: In the case of biomass, Member States shall promote conversion technologies that achieve a conversion efficiency of at least 85% for residential and commercial applications and at least 70% for industrial applications. But is a certification system the best way to improve efficiency? There are several possibilities to implement such efficiency criteria, like: A minimum efficiency could be a condition for eligibility to support funds. This criteria could be part of the licensing procedure for equipments (standards). This criteria could be used in the permitting procedure, when such permit is required. Support programme to progressively replace older technologies by new ones. Verification of the efficiency criteria is also important. We can hardly verify the real efficiency of wood stoves and boilers in houses because it depends very much on the operation of the appliances (air control, low or maximum charge, etc.) and on external factors (quality of the chimney, etc.). Therefore efficiency should be checked once when the appliances are licensed or sold but efficiency can hardly be checked after operation of the systems (at least for small scale). In addition, wood is a cheap fuel that is sometimes the only fuel affordable for poor people. These people are buying cheap biomass appliances with lower efficiencies. If biomass is less attractive because of certification they might burn coal instead. GHG emissions reduction As explained above, the GHG reduction using biomass as compared to fossil fuels is much higher than 35%. Certainly there are differences between small, medium and large scale applications of biomass for heat and electricity. But in general, the room for further improvement is rather small. Before developing a certification system based on the GHG emissions reduction as compared to the fossil standard, it seems better to undertake a comprehensive study about the additional potentials in the reduction of GHG emissions using biomass for heat and electricity in small, medium and large scale applications by improving the existing technologies. The issue of indirect land use change should also be better studied in depth. For GHG emissions reduction as well there are other ways than certification to reach a significant reduction. A carbon tax for example has been very successful in Nordic countries. 9

10 Limited transport distance The smaller the distance between the production site of the biomass and its end-use, the lower are the possible environmental impacts and the C0 2 emissions caused by the transport of the biomass. Therefore there should be a priority to use the biomass locally or regionally. But the transport distance as criteria for sustainability would be in contradiction to the free trade and open market philosophy of the EU and jeopardize those regions with a low endowment of biomass resources. Therefore is should not be used as criteria of certification. Sustainable production Sustainable production of biomass for energy is essential. Yet, according to AEBIOM the sustainable production should be safeguarded within the European forest and agriculture policy, as was already explained in more detail under 3.1 and 3.2. Criteria to be covered by a certification scheme have to be analysed carefully, taking into account the all possibilities to reach the same objective. In the case of C0 2 reduction a better knowledge about the room for possible improvement should exist, before implementing any certification Efficiency in the use of solid biomass and fossil fuels in bigger applications The comparison with fossil alternative is also relevant. Why should we ban the biomass conversion in relatively low efficient power plant if the use of coal do not have to follow the same rule? The energy system in Europe should be driven towards higher efficiencies, whatever the fuel. It would be wise to implement an efficiency threshold for any new power plant in Europe. Such measures would bring much more results for energy efficiency and CO 2 savings in Europe than a certification of biomass. If certain rules are proposed to improve the efficiency of the use of biomass and the C0 2 reduction impact then similar rules have to be applied to the use of fossil fuels. Otherwise, there is no level playing field and the use of solid biomass would be hampered to the advantage of fossil fuels. Evaluation of the system of co-firing of biomass: The co-firing of biomass instead of coal in an efficient combined heat and power plant reduces the C0 2 emissions a lot and warrants a highly efficient use of biomass. This is not the case in a power plant not using the heat. The loss of renewable energy in such a system is considerable. If the lost quantity of biomass in an inefficient co-firing system is used in an efficient way the reduction of C0 2 emissions would be at least the same and the contribution to the energy security would be much bigger. In general, there should be more emphasis to reduce the inefficiencies in the energy system, what also means a more decentralized energy system in which the derived heat can be used more easily. In Nordic and Baltic countries the combination of biomass and peat is essential. Cofiring of peat with biomass improves the efficiency of using poor quality biomass. Efficiency of power improves by 6-8%. Operational experience and previous research have demonstrated that co-firing wood fuels with peat significantly prolong the life time of super heaters, and minimize the occurrence of bed agglomeration in fluidizing beds. Positive effects when co-firing biomass with peat fuels have been achieved by adding 5 30 % peat (on basis of the dry content of the fuel) to wood fuels. 10

11 Therefore a high level of efficiency and C0 2 reduction should be reached in the transformation from primary to final energy independent of the used fuel! It is recommended for the future not to build new power plants with an efficiency below a certain threshold (for example 50%), being the feedstock fossil or renewable. This also should be valid for coal fired power plants using the CCS technology Imports of biomass It is probable, that the imports of solid biomass from outside the EU will have an increasing importance in the future. It might also be possible that the raw material used to produce pellets, chips, etc for sale to the EU does not come from sustainable managed forests, unless there is a policy to prevent such imports. To avoid such a development different concepts are possible, such as: - a voluntary system of certification used by those companies that are importing solid biomass from outside the EU. - Trade contracts between the European Union and third countries, that would like to import solid biomass to Europe. These contracts would have to safeguard the sustainable production of solid biomass in these countries Keep costs reasonable Certification schemes entail some costs both for (eventually) adapting the value chain to the criteria and for administration of the system (chain of custody, analysis, audits, etc.). Such costs might impact the bioenergy businesses. Several remarks can be made: Biomass fuels are low value products (typically less than 100 /t, more for refined biomass like pellets) and additional costs will become quickly significant. Why should small forest owners sell low value by-products from thinnings and logging residues if they have to pay additional charges and fulfil administrative requirements because of this? Costs are closely linked with the size of the project/quantity of biomass, because of some fixed costs independent from quantities. Based on the polluter pays principle it would be logic to fund a sustainability scheme with a tax on fossil fuels rather than making the bio-energy value chain less competitive. Another financing possibility is to ask consumers to support these costs, directly or through public funds. Experience from existing forest and agriculture certification schemes are typical. The cost/benefit balance for forest owners to sign up for a certification scheme is not obvious when selling price for forest products is considered. Selling prices of agricultural commodities produced under cross compliance rules are exactly the same as for imported products without any environmental rules, what is unfair. 5. Conclusions and recommendations 5.1. No mandatory certification system 11

12 A comprehensive mandatory system of rules, checks and controls on international, national and regional level to warrant a sustainable production of biomass is already implemented and working in Europe. A second similar parallel system does not make sense. To safeguard an efficient, C0 2 reducing conversion of the primary energy in biomass to final energy requires a differentiated concept adapted to the different biomass types to energy chains: o small scale heat: standards for boilers, programs to replace old inefficient boilers by new ones, norms for pellets. o district heat: financial programs to improve the efficiency of existing systems and to build new ones, o electricity from biomass: new plants using solid biomass or fossil fuels producing electricity should reach a minimum efficiency of 50%. Weighing all the arguments in favour for and against a certification system for solid biomass to energy AEBIOM recommends not to introduce a general mandatory system for the certification of biomass for energy at present. The main arguments for this position can be summarized as follow: As biomass for heat and electricity is mainly used as by-product, it makes more sense to look at agriculture and forestry as a whole and regulate issues of sustainable production within the agricultural and forest policy rather than within the energy policy. Different C0 2 thresholds for liquid bio-fuels and solid biomass would be a discrimination for the use of solid biomass, on the other hand a threshold of a minimum C0 2 reduction of 35% or 50% would not change anything, except creating additional costs for biomass. Given the millions of stakeholders the costs of a certification system in many cases would be higher than the possible benefits. Strict rules for the certification of solid biomass could become a new barrier for the production of biomass and lead to a reduced supply and thus encourage the increased use of fossil fuels, which leads definitely to a more unsustainable energy system than using biomass Starting with a voluntary system As it would be risky to implement mandatory sustainability criteria from the beginning without knowing the consequences in terms of practical feasibility (costs of the schemes, biomass availability and prices, reaction of market players, impact on renewable production and job creation) it makes sense to start with a voluntary system. Companies could be encouraged to step in the certification, by offering them advantages in terms of visibility or some kind of public support. In other words, the carrot is better than the stick! But giving visibility and create acceptance of a label/scheme require large efforts and budgets for communication programmes by public authorities. The voluntary character of the system also applies to member states. Some countries like The Netherlands and United Kingdom have lower biomass resources and large harbours. They are counting on imports of large volume to meet their targets and they should be allowed to implement sustainability schemes on their territory. 12

13 5.3. Clear rules for imported biomass Imports of solid biomass to the EU will be necessary in the future. It has to be secured that these imports come from sustainable managed forests and these countries follow the principles of sustainability in their primary production as outlined at the beginning of this paper. Voluntary certification schemes by countries or companies are recommended to warrant a sustainable production of imported biomass A comprehensive study on the potential of GHG emissions reduction AEBIOM estimates that in many cases the reduction of GHG emissions using biomass for heat as compared to the fossil standard lies above 90%. In the case of electricity it might be similar. These data are based on the calculation of a few individual projects. To our knowledge a comprehensive study on this issue seems not available. Therefore it is recommended to carry out such study, to better evaluate the potential for improvements by different technologies and sectors (on a life cycle analysis base) and the possible impact of certification Respecting level playing field Fair treatment is required in several fields : Fossil fuels are free from any certification scheme and nothing is considered in the short/medium term. Any financial and administrative burden on biomass would reduce its competitiveness. Farmers and forest owners should have the same rule for the same products. The pulp and paper sector is working with voluntary schemes according to corporate governance rules and client's requests. There is no reason to go beyond these rules for bioenergy plants. Rules for efficiency of the conversion of biomass should be applied to fossil fuels as well. Rules for biomass imported and produced in Europe should be similar to avoid unfair competition. 13