Download RED consultation

Governmental use of sustainability
standards:
examples & lessons from the UK RTFO
ISEAL conference, Zurich, 8 June 2011
Dr Keeley Bignal - Sustainability Technical Guidance Specialist
RTFO Unit, Low Carbon Fuels, UK Department for Transport
Overview
•
•
•
•
UK biofuel policy
C&S reporting
RTFO Biofuel Sustainability Meta-standard
Benchmarks of sustainability schemes against
the Meta-standard
• Benchmarks against the RED carbon stock and
biodiversity criteria
• Uptake of standards by suppliers of biofuel to
the UK
• Lessons learnt
UK biofuels policy: the Road
Transport Fuel Obligation
• Introduced in 2008
• Duty point obligation
• 2.5% biofuel volume
rising to 5% 2013
• Tradable certificates &
buy-out option (30ppl)
• Carbon &
sustainability reporting
Carbon & sustainability reporting
scope
Carbon & sustainability reporting
overview
• To claim RTFCs C&S reports must be supplied
• C&S data must be independently verified
• Annual targets for company performance (no penalty for failing
to achieve)
Company targets
20082009
20092010
20102011
Percentage of feedstock meeting the ‘Qualifying’
Environmental Standard
30%
50%
80%
GHG saving
40%
45%
50%
Data provision
50%
70%
90%
C&S reporting
- the 'RED-ready' approach
• RTFO C&S reporting adapted to be as consistent as possible
with the EC requirements from the start of the third year of the
RTFO on 15 April 2010
• Aim to help UK industry best prepare for the RED
• Aim to be transparent about which batches of fuel are
indicatively RED-ready
• RTFO continues to require C&S reporting rather than
mandatory minimum performance until RED implementation
Benchmarks of sustainability assurance
schemes against the RTFO Meta-Standard
Principle
Environmental
Conservation
of carbon
Conservation
of biodiversity
Soil
conservation
Sustainable
water use
Air quality
Social
Workers
rights
Land rights
Bonsucro RSPO RTRS
Red RSB SA8000
Tractor
Proterra
The norm for Qualifying Standards
• Qualifying Environmental Standard:
– Full compliance with all criteria referring to compliance with
national legislation (2.1, 3.1, 4.1, 5.1);
– On all principles one ‘partial compliance’ criterion is
permitted per principle, with a maximum of three in total.
• Qualifying Social Standard:
– On principle 6, seven of the 11 criteria must be fully
complied with;
– On principle 7 on land right issues and community relations,
one partial compliance is permitted.
The norm for audit quality
Criterion
Norm
Conformance
ISO Guide 65: 1996, ISO 17021: 2006, or justified equivalents
MAJOR MUST
2. Management of
the audit programme
ISO 19011: 2002, or justified equivalent
MINOR MUST
3. Audit frequency
Once every 5 years for a full certification audit and once a year for a
surveillance audit
MAJOR MUST
ISO 19011: 2002, or justified equivalent
MAJOR MUST
Specific requirements relevant to the product that the CB is certifying
should be added as training requirements where appropriate.
MAJOR MUST
5. Stakeholder
consultation
To include a range of relevant stakeholders.
MINOR MUST
6. Public summaries
of the certification
audit
To include overall findings of the certification audit, any details of noncompliance and any issues identified during the stakeholder consultation.
Information should be available in both English and the relevant local
language(s), if applicable.
MINOR MUST
Certification
1. Requirements for
CBs
Audit
4. Audit competency
Accreditation
Benchmarks of sustainability schemes
against the RTFO Meta-Standard
Principle
Bon RSPO RTRS
Red
RSB SA8000
sucro
Tractor
Proterra
Environmental
Conservation
of carbon
Conservation
of biodiversity
Soil
conservation
Qualifying
standards
Not
qualifying
standards
Sustainable
water use
Air quality
Social
Workers rights
Land rights
Qualifying
standards
QS
Not
qualifying
standards
Indicative RED Benchmark
Red
Tractor
Ref date (biodiversity)
Primary forest
Nature protection
Ecosystem protection
Natural grassland
Species rich nonnatural grassland
Ref date (carbon)
Wetlands
Continuous forest
10-30% canopy forest
Ref date (peatland)
Peatland
FSC
Genesis
LEAF
RSB
+RED RSPO
RTRS
(draft)
SAN/
RA
Key gaps & challenges
• No operational sustainability schemes currently assess GHG
savings – though some are in development
• At time of RFA assessment only two schemes were strong
enough on LUC to meet RED criteria on preservation of
carbon stocks – some have now developed EU ‘add-on’
modules to cover this
• Many key biofuel feedstocks are not covered by an operational
sustainability scheme
• Few cover the chain of custody – some are in development
Monthly reporting format – using
sustainability standards to identify REDreadiness
RED-ready
Indicative
REDready
Plant in operation on
23 Jan 2008?
GHG
Biodiversity
C-stock
Accuracy level
Carbon intensity
g CO2e / MJ
Land-use on 1
Jan 2008
Carbon
informa
tion
Social Level
Env. Level
Standard
NUTS 2
compliant region
Biofuel
Production
Process
Biofuel
Feedstock
Quantity of fuel
(litres)
Fuel type
Internal Batch
no. (optional)
Bat
ch
No.
Country
Country of
Sustainability
origin
information
information
General
information
3301
Bio250,000
ethanol
Wheat
Unk
UK
Y
LEAF
QS
-
Cropland –
70
nonprotected
1
Y
Y
Y
Y
Y
3302
Bio100,000
ethanol
Wheat
Natural
gas CHP
France
FR51
RED Biodiv
-
-
Cropland –
44
protected
2
N
Y
Y
Y
Y
3303
Bio250,000
ethanol
Sugar
beet
-
UK
N
ACCS
QS
-
Cropland –
non40
protected
6
Y
Y
Y
Y
Y
3304
Bio1,000,000
ethanol
Sugar
cane
-
Brazil
N/A
RTFO
Cropland –
MetaRTFO RTFO non24
Standard
protected
1
Y
Y
Y
Y
Y
3305
Bio500,000
ethanol
Unk
-
Unk
Unk
Unknown -
0
Y
Y
N
N
N
3306
Biodiesel
1,000,000
Oilseed
rape
-
UK
Y
ACCS
1
Y
Y
Y
Y
Y
3307
Biodiesel
250,000
Oilseed
rape
-
Unk
Unk
Unknown -
1
Y
Y
N
N
N
-
Unknown
115
Cropland –
RTFO RTFO non52
protected
-
Unknown
52
Moving sustainability forward
• RFA contacted standards bodies with recommendations ‘simple’ updates in many cases to align with RED:
– inclusion of reference date for LUC
– aligning reference date with Jan 2008
– more explicit and specific on carbon conservation
requirements
• Several schemes are progressing quickly to cover key
feedstocks – e.g. RTRS, BSI, ISCC, RSB
• Several schemes are developing EU market access/ RED
add-ons in response to market demand/regulatory framework
• RTFO Meta-Standard can be used in absence of operational
assurance schemes
Biofuels supplied under the RTFO† - performance against the
targets
Annual supplier target
Year 3
Target
Actual
Year 2
Target
Actual
3.29% 3.25% 3.33%
Year 1
Target
Actual
2.5%
2.7%
% of road transport fuel
3.5%
% of feedstock meeting
a Qualifying
Environmental Standard
80%
49%
50%
31%
30%
20%
Annual GHG saving
50%
55%
45%
51%
40%
46%
Data capture
90%
82%
70%
72%
50%
64%
Year One = 15 April 2008 – 14 April 2009
Year Two = 15 April 2009 – 14 April 2010
Year Three = 15 April 2010 - 14 April 2011
Environmental sustainability
Year One
Year Three
Proportion of biofuel meeting sustainability
standards
100%
None/
unknown
90%
Other
Standards
80%
70%
51%
50%
Qualifying
Standards
60%
Year Two
50%
0%
8%
RTFO MetaStandard
40%
30%
40%
33%
20%
10%
0%
8%
8%
Environmental
Social
N.B. provisional data 2010/11 obligation year-to-date. Quarter 11.
Company performance – Year One
Environmental sustainability
by company
Company performance – Year Two
Environmental sustainability
by company
Company performance – Year Three
90%
80%
70%
at or above
target
<10% from
target
>10% from
target
target
60%
50%
40%
30%
20%
10%
Greenergy
Lissan
Petroplus
Harvest
BP
Chevron
Shell
Total
Esso
Topaz
Mabanaft
ConocoPhillips
Morgan Stanley
INEOS
Prax
Murco
0%
N.B. provisional data
2010/11 obligation yearto-date. Quarter 11.
Proportion of fuel meeting a qualifying environmental
standard
Environmental sustainability
Proportion of fuel meeting a qualifying environmental standard
100%
by company
Key RED
sustainability features
• 35% GHG savings
• Cross-compliance
• High carbon stock protection*
– Wetlands
– Peatlands
– Continuous forest
• High biodiversity protection*
– Undisturbed primary forest
– Conservation areas
– Biodiverse grassland
*Post Jan 2008
RTFO data – are we
ready for RED?
First 9 months of Yr 3
• 71% of biofuel met the
35% GHG saving
threshold (may not have
met all sustainability
criteria e.g. unknown land
use)
• 13% from unknown land
use
• 49% met an
environmental standard
Lessons learnt
• The standard must be fit for purpose e.g. a scheme may be
designed for food safety but not for environmental
sustainability
• Engage the standard owner
– Inform them of process and purpose of benchmarking
– Ensure you have the latest (and all) documentation
– Inform them of the results before finalising
– Can work with the standard owners to drive sustainability
• Consult with experts and stakeholders on benchmark results
• Be realistic – set the ‘standard’ you are aiming for but
recognise that there may be interim steps to get there
• Get ‘buy-in’ from stakeholders – need the fuel suppliers and
supply chain to provide the demand for sustainability
schemes
Lessons learnt
• Voluntary C&S reporting works
– Uptake of sustainability schemes has
increased over time
– Providing public access to data has driven
individual companies to improve performance
• Voluntary reporting can provide a ‘stepping
stone’ to mandatory sustainability