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.

For more information, please contact:

Melanie Wedgbury (SBP)
T: +44 (0)7734 793279