Call for Proposals: Regional Risk Assessments

SBP is inviting qualified and experienced organisations/individuals to submit proposals for the development of SBP-endorsed Regional Risk Assessments (RRAs) for the Socialist Republic of Vietnam and the key biomass producing states of the USA.

RRAs are a key part of SBP’s focus on identifying and mitigating risks associated with sourcing feedstock. There are many benefits to determining the risks associated with sourcing feedstock from an entire region, in terms of consistency across Biomass Producers and Certification Bodies, level of effort and active engagement with a diverse range of stakeholders.

SBP is seeking to collaborate with a reputable partner/s to act as a Working Body/ies in the development of the RRAs and provide valuable insights into the sustainability risks associated with feedstock sourcing and biomass production in these key sourcing areas.

Interested parties are requested to submit their proposals by 30 November 2023. Proposals should be submitted electronically to info@sbp-cert.org. Further details and guidelines on the submission process are available here.

SBP Public Consultation on SDE+ Instruction Documents

The Sustainable Biomass Program (SBP) has today launched a public consultation on two Instruction Documents that allow SBP Certificate Holders to demonstrate compliance with specific biomass sustainability requirements of the Netherlands SDE+ subsidy regime.

Following the development of the SBP Standards v2.0, it has been necessary to update Instruction Documents 2D and 2E and seek the approval of the Dutch authorities. As part of that approval process, we now invite stakeholders to review and submit comments on the requirements of these two documents (links to the documents are given below). The deadline for comments is Friday, 3 November 2023.

All feedback should be submitted to Roman Polyachenko.

Instruction Document 2D specifies the requirements for the evaluation and certification of group schemes for the purpose of demonstrating compliance with the Netherlands SDE+ requirements for biomass categories 1 and 2. Minor changes have been introduced in v2.0, including:

  • the group scheme now only applies to SDE+ biomass categories 1 and 2, rather than 1 to 4 under v1.0
  • a reference to Instruction Document 3I: SBP requirements for Certification Bodies auditing SBP group schemes has been added
  • definitions and references have been aligned with those in the revised SBP Standards v2.0

Instruction Document 2E specifies the requirements for the evaluation, using a risk-based approach, of the Netherlands SDE+ requirements for controlled biomass categories 1 and 2. Minor changes have been introduced in v2.0, including:

  • the risk-based approach is only available for SDE+ controlled biomass, rather than SDE+ compliant biomass
  • definitions and references have been aligned with those in the revised SBP Standards v2.0

Following the public consultation, we will review the input, finalise the Instruction Documents and submit them to the Dutch authorities for final review and approval. We anticipate that the two Instruction Documents will be approved and published by the end of the year.

SBP recognised by the Government of Japan

The Sustainable Biomass Program (SBP) has been recognised by the Government of Japan as meeting the requirements necessary for confirming both the life-cycle greenhouse gas emissions of imported woody biomass under Japan’s Feed-in Tariff (FIT)/Feed-in Premium (FIP) System for Renewable Energy, and the legality and sustainability of imported wood in line with guidelines set under the Clean Wood Act.

Carsten Huljus, SBP Chief Executive Officer, commented: “This is very welcome news. We have long identified Japan as a growth market for biomass end-use and importantly one that is committed to sustainability in the sector. We are pleased to receive the recognition that will enable Certificate Holders in Japan to utilise the existing global supply chain of SBP-certified biomass and increase the volume of sustainably sourced material in the market.”

The Ministries of Economy, Trade and Industry (METI) and Agriculture, Forestry and Fisheries (MAFF) are responsible for the FIT/FIP System and Clean Wood Act, respectively.

Working with the Government of Japan’s appointed representatives, SBP has drafted a dedicated Instruction Document that will enable Certificate Holders to meet the Japanese requirements and allow SBP-certified biomass to be imported and used by Japanese power generators. The Instruction Document is expected to be finalised by the end of the year following a review by the SBP Technical Committee and approval by the Japanese Biomass Sustainability Working Group.

SBP will offer training to all Certificate Holders to ensure smooth and effective implementation of the requirements. Further information will be made available in due course.

SBP Publishes its Annual Review for 2022

The Sustainable Biomass Program (SBP) has today published its annual review for 2022. The review is available at: www.sbp-cert.org/documents/annual-reviews.

Commenting on the events of 2022, Carsten Huljus, SBP Chief Executive Officer, said: “The end of the year marked the end of our three-year strategy, which commenced in 2020. Through the delivery of our strategic aims we have positioned SBP as the woody biomass certification scheme of choice, maintained our relevance in the marketplace, enabled informed and responsible choices throughout the supply chain, kept up-to-date with best practice, and informed the biomass debate.

“We saw a drop in Certificate Holder numbers as economic sanctions were triggered by Russia’s invasion of Ukraine and, accordingly, we terminated certificates in Russia and Belarus. The resultant drop in revenue was countered by our cash reserves with no detrimental impact on our certification services.

“Our geographic reach increased from 33 countries to 34, with the loss of Belarus and Russia offset by the gain of Réunion, Singapore and South Africa.

“The volume of SBP-certified biomass produced and sold in 2022 dropped to 15.95 million tonnes (2021: 16.70 million tonnes), consistent with the decrease in Certificate Holder numbers. Our share of the European industrial pellet consumption market1 was 78.9%, down from 82.5% in 2021.

“Once again analysis of the wide range of data we collect provides valuable insights on exactly what is used to make SBP-certified biomass. Independently verified data for 2022 shows that the vast majority of feedstock used in the production of biomass came from low grade roundwood that was not merchantable as sawtimber, and sawmill and wood industry residues.

“For the first time we were able to determine the split between forest-level certified feedstock and feedstock evaluated using our own risk-based approach. With the majority of feedstock having been evaluated by our Supply Base Evaluation, the positive impact SBP is having on increasing the volume of certified material in the biomass market is evident.

“With a refreshed strategy for 2023-25, and the roll-out of our revised and improved Standards, we are well-placed to take a leadership role in assuring sustainably-sourced biomass in the global bioeconomy”.

SBP Directorate Change

Raul Kirjanen, founder of AS Graanul Invest, has with effect from 14 June 2023 stepped down from his role as a board member of the Sustainable Biomass Program. Mr Kirjanen has served in this position in a personal capacity since January 2022 and we thank him for his valuable contribution to our organisation. We will be recruiting a new board member to represent Biomass Producer interests over the coming months and will provide an update in due course.

SBP Publishes Strategy for 2023-25

SBP has today published its Strategy for the three-year period ending 2025. It comprises a refreshed statement of Purpose, four Strategic Aims, and five Focus Areas for delivery.

Francis Sullivan, SBP Chair, commented,: “Our Strategy draws on our past but chiefly looks to the future. It explains our Purpose, defines what we mean by good biomass and sets out our ambitions and commitments as a framework for our annual investment and operational plans.

“We set out the indicators by which we will assess our success over time in strengthening our position as the woody biomass certification scheme of choice and as a vehicle for positive impact.

“As a sourcing standard, we support those active in the woody biomass supply chain who are in it for the long term, and who understand the importance of the triple bottom line. We are confident that we make a compelling case for broader adoption of our Standards and for broadening and deepening our relationships with all our stakeholder groups”.

The full strategy and a summary document can be found here.

Better than Before: SBP Launches Revised Standards

SBP has today launched its revised sourcing Standards for woody biomass. The revised Standards underpin the SBP promise of good biomass. They require that SBP-certified biomass is deforestation-free, that biodiversity is maintained or enhanced through protecting key species, habitats and ecosystems, that water quality and soil quality are maintained or enhanced, that carbon stocks are stable or increasing, and that workers and their rights, local communities, and the rights of Indigenous Peoples are protected.

In addition, the EU REDII requirements will be mandatory for all Certificate Holders certified against the revised Standards.

Carsten Huljus, Chief Executive Officer, commented: “Reviewing and revising our Standards has been another milestone in the development of SBP.

“At the outset our goal was to achieve multi-stakeholder consensus on how to improve and advance our certification scheme, whilst maintaining relevance and effectiveness, and importantly, ensuring future fitness.

“We have achieved that with a set of Standards that are better than before, and we are now focused on their successful roll-out.

“My sincere thanks to all who contributed along the way”.

The Standards Development Process

The launch of the revised Standards marks the culmination of the Standards Development Process that we and our stakeholders formally embarked upon in 2020, five years since our Standards were first published.

Continuous improvement and relevance are central to our thinking and a key aspect of the review and revision process was to fully consider, amongst other things, changes in market regulations, advances in best practice, and increased knowledge of key issues, including forest carbon, biodiversity and social impact.

The Process encouraged full stakeholder participation, with comprehensive Working Group arrangements to delve into the detail and make recommendations to improve and advance the requirements for legal and sustainable sourcing of feedstock for biomass production.

The full suite of six Standards was subject to three public consultations, and pilot testing in key producer regions across a representative sample of small and large producers of pellets and chips.

Our Technical Committee and Standards Committee conscientiously oversaw the Process, scrutinising the recommendations throughout. Ultimately, in March 2023, following approval by the Standards Committee our Board endorsed the revisions.

Key improvements

Our revised Standards have been improved and advanced in a number of areas, including:

  • Structural, streamlining our requirements to aid implementation and clarity, with a focus on outputs.
  • Beyond regulatory compliance, through indicators in the areas of biodiversity, land conversion, forest carbon stock, cascading use, training, grievance handling and free, prior and informed consent (FPIC).
  • Environmental, strengthened requirements to identify threats to ecosystems, and to maintain or enhance key species, habitats, ecosystems and areas of high conservation value; clarifying those no-go areas of land that cannot be changed or converted; regeneration of forested land; and banning of harmful agrochemicals.
  • Forest carbon, a new principle, including land use, land-use change and forestry (LULUCF) emissions requirements; driving positive impact through the requirement for forest carbon to be stable or increasing; no harvesting in low productivity or difficult to regenerate areas, nor in areas combining high conservation values and high carbon stocks; and the introduction of the cascading use principle.
  • Social, new and enhanced social requirements fighting discrimination through strengthening the protection of workers and their rights; and requirements to identify and avoid negative impacts in local communities, protect cultural heritage sites and the rights of Indigenous Peoples.
  • Identifying and managing sourcing risks, a major overhaul delivering greater clarity in how to develop, implement and manage risk assessments, and the introduction of more objective requirements for auditors when evaluating compliance; a new concept of benchmarked and recognised schemes to manage risks in the Supply Base; and the need for requirement for stakeholder consultation.
  • SBP-specific, increased relevance of the requirements for Certification Bodies and the introduction of our own Chain of Custody system; strengthened requirements around auditor competence; minor and major non-conformity definitions aligned with best practice; and clear rules on, amongst other things, annual surveillance audits, audit timelines, management systems and internal audits, record keeping, stakeholder consultations, health and safety, and anti-corruption.
  • Data focused, significant improvements to the requirements around identifying volumes of biomass and communication of data; and enabling the calculation of greenhouse gas emissions along the supply chain.

A fuller description of the improvements and advancements is available here.

Roll-out of SBP Standards v2.0

All documents come into effect on 10 August 2023, and  existing Certificate Holders have a period of 15 months from the effective date during which to transition to the revised Standards. The transition period will end on 9 November 2024, at which time SBP Standards v1.0 will be retired.

The normative documents, comprising the six SBP Standards, Glossary of Terms and Definitions, and Instruction Documents are available on our website here. For the first time we have published Guidance Documents to accompany Standards 1, 2 and 4, and they are available on our website here.

SBP-endorsed Regional Risk Assessments (RRAs) are currently being revised, and new RRAs developed, to align with the revised Standards. Keep up-to-date with the status of the revisions and developments here (scroll down).

SBP Directorate Change

Will Gardiner, CEO of Drax Group, has with effect from 16 March 2023 stepped down from his role as a board member of the Sustainable Biomass Program. Mr. Gardiner has served in this position in a personal capacity since January 2019 and we thank him for his valuable contribution to our organisation. We will look to filling his seat over the coming months and will provide an update in due course.

SBP Revised Standards (v2) Approved

SBP has today announced that following approval by the Standards Committee, the Board has formally endorsed the revised SBP Standards (v2).

Approval of the revised Standards concludes the Standards Development Process that was launched in May 2020. Amounting to a significant effort, the Process was designed to encourage and realise a wide-ranging review and, where necessary, revision of the Standards with full stakeholder participation.

Advances in the understanding of sustainability issues, market requirements and international best practice for effective and credible certification schemes were key considerations during the review and revision.

Our revised Standards underpin our promise of good biomass, requiring that SBP-certified biomass is deforestation-free, that biodiversity is maintained or enhanced through protecting key species, habitats and ecosystems, that water quality and soil quality are maintained or enhanced, and that carbon stocks are stable or increasing.

Martin Junginger and Mike Williams, Co-Chairs of the Standards Committee, commented: “With responsibility for the approval recommendation, we devised guiding principles for the review and revision, and evaluation criteria against which to test the revised Standards. With equal representation of civil society and commercial interests we were able to bring balance to the Standards Committee’s decision-making. We are confident that a strengthened and credible set of Standards has been delivered, serving the interests of SBP’s wide-ranging stakeholders”.

In the early stages of the Process, three multi-stakeholder Working Groups and various topic-specific Sub-groups delved into the detail of the Standards and made proposals and recommendations for revision. Public consultations and pilot testing supplemented development of a suite of draft Standards that were then subject to intense scrutiny by the Technical Committee and Standards Committee.

Carsten Huljus, Chief Executive Officer, commented: “We have called upon our many and varied stakeholders throughout the review and revision, amassing several thousands of stakeholder hours. I am extremely grateful to all those who have contributed to version 2 of our Standards. What we now have is better than before and provides a solid foundation for future growth”.

The next steps are shown in the timeline below. The pre-release version of the approved Standards is available at: https://sbp-cert.org/standards-development/pre-release-version/

 

 

The pre-release version of the Standards has been released to facilitate the development of new, and the revision of existing, Regional Risk Assessments, and for submission to regulatory authorities to maintain our current approvals.

Please note that the ‘Pre-release publication date’ does not start the clock as far as the ‘Effective date’ and ‘Retirement of SBP Standards (v1)’ are concerned. The ‘Publication date’ (see timeline) marks the formal publication of our revised Standards and is the key anchor date for the steps that follow.

SBP Response to NGO Briefing Paper, ‘Sustainable Biomass Program: Certifying paperwork without looking at the forest’

The recently published NGO briefing paper, ‘Sustainable Biomass Program: Certifying paperwork without looking at the forest’, alleges that the Dutch authorities’ decision to deem all SBP-certified wood pellets as meeting national sustainability and greenhouse gas standards is unjustified.

SBP welcomes constructive criticism of its certification scheme, which is used to improve its Standards, processes and procedures. SBP is also interested in any feedback regarding its Certification Bodies and Certificate Holders. Allegations of non-compliance are taken seriously and, in the first instance, are drawn to the attention of the relevant Certification Body.

SBP is approved under the Dutch SDE+ subsidy regime, which has specific biomass sustainability requirements and a comprehensive approval mechanism that together should give stakeholders confidence in the decision to deem SBP-certified biomass as SDE+ compliant.

To become SBP-certified, a Biomass Producer (or Trader or End-user) must comply with the SBP Standards. If an SBP-certified Biomass Producer wishes to sell biomass into the Dutch biomass market then it must comply with additional SDE+ requirements specific to the Dutch biomass market. SBP has developed and implemented two additional Instruction Documents to address the specific nature of the SDE+ requirements.

When external bodies compare the SBP Standards with the SDE+ requirements, they too must look at the SDE+ Instruction Documents. The NGO briefing does not appear to have taken those additional documents into consideration.

SBP has evaluated the allegations made in the NGO briefing and finds them to be unjustified. The NGO briefing claims to identify four key problems with SBP, each are addressed below.

  • Lack of external auditing of forest management linked to pellet production

The SBP scheme requires independent, credible auditing of supply chains or verification of claims made by Biomass Producers. SBP Standard 3 establishes a protocol for exactly that. The rules are derived from ISO17065 and ISO19011 – internationally recognised standards for auditing that are applied across many sectors globally. Further, SBP is a community member of ISEAL and SBP Standard 3 is based on the ISEAL Assurance Code of Good Practice.

SBP has clear and proportionate auditing requirements in place. SBP-certified Biomass Producers must undergo an annual audit by an independent Certification Body. SBP operates a risk-based approach, which is a well-known and accepted approach for certification schemes. Independent auditors verify how Biomass Producers manage the specified risks within their supply base, which will entail field visits.

It is important to note that SBP is a sourcing standard, it is not a forest management standard. SBP recognises feedstock accompanied with an FSC, PEFC or PEFC-recognised scheme claim as SBP-compliant.

  • Lack of appropriate scrutiny of claims made by pellet producers and information sources provided by them

The SBP certification scheme requires appropriate scrutiny of claims made by Biomass Producers and information sources provided by them. There are, in fact, four levels of scrutiny:

  1. Independent Certification Bodies – whose auditors must have the requisite skills and training to undertake audits of SBP Certificate Holders. The role of an auditor is to precisely verify the claims made by Biomass Producers and information sources provided by them;
  2. Stakeholder consultation – SBP requires that stakeholders are consulted both by Certificate Holders and Certification Bodies;
  3. Peer review – SBP requires that the findings of the auditors are peer-reviewed by an independent expert; and
  4. Independent accreditation body – whose role is to assess the Certification Bodies through witness assessments of the audits undertaken by the Certification Bodies.
  • Inconsistent interpretation of evidence by certifiers

SBP-endorsed Regional Risk Assessments (RRAs) cover an entire geographic region or country and are a key part of SBP’s focus on identifying and mitigating risks associated with sourcing feedstock. Each country has its own legal framework and resources to support compliance with the SBP requirements, and they naturally vary from country to country. It would be highly unlikely for all countries’ risks to be rated the same and, therefore, it is not unusual to see risk ratings of the same indicators differ across borders. For that reason, the suggestion that RRAs for two different countries contradict each other cannot be attributed to inconsistent interpretation.

  • SBP indicators, i.e., guidelines for interpreting criteria, are not compatible with SDE++ criteria

The Dutch authorities continually monitor SBP’s activities. SBP is obliged to provide the authorities with updates made to any of the scheme’s documentation for their evaluation, whether Standards, SDE+ Instruction Documents, guidance, or interpretations. Maintaining the approval of its certification scheme under SDE+ is important to SBP and its Certificate Holders, and SBP works hard to assure compliance with the SDE+ requirements.

Note: SBP is compliant with SDE+ requirements (renewable energy production). SBP has not sought approval under SDE++, which supports other technologies for reducing greenhouse gas emissions.

In conclusion, SBP is a credible and robust certification scheme for woody biomass. It is recognised by leading regulatory regimes, aligned with best practice for sustainability sourcing standards, and incorporates thorough, independent scrutiny of all practices and decisions.

SBP would welcome the opportunity to engage with the authors to discuss the topics in more detail.