Biofuels under attack - Germany's Best Practice Certification to the rescue

With the growth of bioenergy across the globe, the debate over its relevance and impact has intensified, pitting the industry and bioenergy's diverse adherents against climate campaigners, critical scientific organizations, and even the likes of the European Commission's DG Climate. The proponents say that the shortcomings of bioenergy production can be ameliorated with regulation, such as certification schemes that set rigorous sustainability criteria. Germany was the first to push for such regulation at home and on the European level. Today it has two schemes in place that are considered best practices in Europe and beyond, and are perhaps even applicable to other sectors. These programs could prove the saviour for an industry that is simultaneously surging and under attack. From Berlin Paul Hockenos reports.

The shortcomings of bioenergy production can be ameliorated with regulation, proponents say (c) Farmers Weekly Interactive
The year 2012 was not kind to Germany's large bioenergy industry, the biggest in Europe, despite the fact that it grew moderately in size and managed to further ramp up production. In addition to the array of high-profile NGOs that damn biofuels (biogas, bioethanol, biodiesel) as an environmental hazard, a poor harvest this year in key grain growing regions worldwide sent food prices soaring and stoked renewed angst about food shortages. Among other critical reviews, an International Council on Clean Transportation study concluded that most crop-based biofuels had a bigger carbon foot print than most fossil fuels and urged the EU to review its bioenergy policy.

Throwing fuel on the fire, Germany's reputed national scientific academy, the National Academy of Sciences Leopoldina, issued a scathing report this summer on biofuels that landed on the front pages of major newspapers. A group of 20 experts from various disciplines branded the sector as a bit player in the transition to renewables and charged that its net environmental impact is negative. The cultivation and use of energy crops, it concluded, leads to high emissions of greenhouse gases, damages ecosystems, and competes with food crops. Germany's biomass imports, argued the scientists, effectively export the harmful impact of intensive bioenergy-based agriculture. The report recommends bolstering other renewables like PV solar power and wind power, as well as finding strategies for increasing energy efficiency rather than investing further in the bioenergy branch. Bioenergy makes sense, it concludes, only in the limited circumstances when animal or other kinds of waste (residuals) serve as the biomass.

These kinds of charges against the bioenergy sector are not altogether new - nor are the industry's responses to its detractors. Indeed the strongly worded Leopoldina report elicited a barrage of objections calling the report superficial, inaccurate, and disingenuous.

Most stringent in the world

One of the most relevant charges against the "Leopoldaner" was that the report failed to take serious stock of the two biofuels certification schemes in Germany that were designed explicitly to address bioenergy's environmental shortcomings. Germany was the pioneer in designing and implementing these controls at home as well as having standards turned into law for the EU-27. In the German biofuels sector, indeed now across most of EU Europe, only certified biofuel can be used to meet the EU quotas. These standards, say advocates, are legitimate Persilscheine for bioenergy and make biofuel production sustainable in Europe. Europe's certification schemes are "the most stringent in the world," says Günther Oettinger, the EU's energy commissioner.

The brouhaha over biofuels is being taken seriously at the highest levels in Germany for good reason: multitalent bioenergy is a central plank of the Energiewende. Bioenergy's "multi-talents" are highly praised as it can be easily stored in the form of electricity, natural gas, heating oil, and liquid fuel, and

The brouhaha over biofuels is being taken seriously at the highest levels in Germany for good reason: multitalent bioenergy is a central plank of the Energiewende
thus serve as a stabilizer alongside energy mixes dominated by PV and wind, like Germany's. The EU 2020 targets include a 10 percent share of renewables in the transportation sector (5 percent of which can be biofuels). Biofuels are also envisioned to play a significant role in boosting the EU's use of renewables to 20 percent of the bloc's energy consumption and lowering emissions by 20 percent. As for Germany, bioenergy is even more critical, expected to cover 12 percent of transportation's fuel needs (in the form of biodiesel and/or bioethanol) as well as shoulder much heavy work in heating and electricity. It is expected to cover roughly 23 percent of Germany total energy use by 2050.

And it's not just that much is expected of bioenergy: the sector has already become quite important in recent years. Biofuels currently cover 4.5 percent of the EU's transport fuels needs, just short of its (recently adjusted) 2020 target of 5 percent. Since 2005 the use of biodiesel and bioethanol has tripled on the continent. It's a 17 billion euros a year business in Europe, according to the European Biodiesel Board, making it the biggest bioenergy sector in the world.

In Germany different biomass-based energies contribute mightily to the country's impressive renewables figures, accounting for 70 percent of all renewable energy, 32 percent of green electricity, 92 percent of clean heating; and 100 percent of sustainable transport fuel. In 2011 bioenergies constituted 8.3 percent of Germany's total energy production. According to Germany's environment ministry, in 2011 the use of bioenergy saved 61 million tons of carbon emissions.

Industry numbers are also daunting: in 2012 2.12 million hectares of German land hosted energy crops, which is 18 percent of the country's arable cropland. Germany's 1,772 bioenergy enterprises - from small farmers to nationwide utilities - account for 120,000 jobs, many of them in former eastern Germany. This is a powerful sector that German policymakers cannot easily afford to abandon.

Yet the unrelenting critique of bioenergy has thrown its role into question. Sources inside the EC say that convincing expert studies have downgraded the projected emissions savings from crop-based fuels, above all bio-diesel. In response, last year the EC came out with proposals that specified that of

Industry numbers are also daunting: in 2012 2.12 million hectares of German land hosted energy crops, which is 18 percent of the country's arable cropland

the 10 percent renewables it planned to have in transport by 2020, only half could come from biofuels based on food crops. In addition, the Commission has proposed to end all public subsidies for food-based biofuels after the current legislation expires in 2020. According to Reuters news service, this constitutes "a major shift in Europe's much-criticized biofuel policy and a tacit admission by policymakers that the EU's 2020 biofuel target was flawed from the outset." As for Germany, insiders say that in the ongoing discussion about Germany's 2030 Energiewende goals the role of biofuels is being viewed much more critically than in the past.

Prickly questions

Are the new European proposals fair? Is all the criticism of biofuels justified? In particular, don't strict new regulations across the EU and extending into foreign countries verify that Europe's bioenergy is environment friendly? There is no consensus on these prickly questions.

Among the seven EU-approved certification schemes, the German programs are perhaps the most advanced in the world. In force as of December 2011, the two German schemes were the first in the EU coming to life shortly after the Renewable Energy Directive (RED2009/28/EC) went into effect in 2010 across the EU-27. The RED stipulated that EC-approved certification programs must be adopted by every member state. In Germany the Biokraftstoff-/Biomasse-Strom-Nachhaltigkeitsverordnung (biomass sustainability ordinance) entered into force in January 2011 inscribing the RED's criteria into national law. Currently 24 of the 27 members states have installed approved certification programs, be they national programs like the German one or EU template programs.

The EU's legislation's guiding concern is the reduction of greenhouse gases. Biofuels must deliver greenhouse gas savings of at least 35% compared to fossil fuels, rising to 50% in 2017 and by 2018 to 60% for biofuels from new plants. This covers total carbon emissions across the value chain, from production to transportation and processing of all liquid biofuels, including those imported into the EU.
 

Straubing, Germany: pilot plant for climate-friendly cellulose ethanol from agricultural waste (c) Clariant
The German schemes include standards beyond those required by the EU, such as norms for working conditions, anti-discriminatory practices and child labour. They also aim to ensure sustainable land use, protection of natural habitats and social sustainability. Thus, they stipulate that biofuels may not come from forests, wetlands, and nature protection areas. They also have provisions to prevent what is called indirect land-use change (ILUC), for example when rain forests are converted into palm oil plantations to grow feedstuff for biofuels. Nor do they allow carbon-rich areas, like tropical forests, and regions with high biodiversity to be used for biomass cultivation. Moreover, biomass will not be certified as sustainable if the purpose of the land's use has changed after 2008 (direct land-use change).

Germany has two verification schemes run by private agencies that operate under the authority of the Federal Agency for Agriculture and Food (BLE). The Cologne-based International Sustainability & Carbon Certification (ISCC) is primarily responsible for the guidelines for the verification of biomass and biofuels outside German borders while REDcert covers biofuel certification primarily in Germany.

It works like this. Upon request, ISCC or REDcert bring together a bioenergy producer and one of several dozen nationally accredited (BLE) certification bodies across Germany or, if the producer is located abroad, with a BLE-accredited agency in that country. The inspectors from the agencies travel to the operators who seek certification. The auditors inspect the production, processing, and buying and selling of biomass at every station along the value chain - from the farmer to the mill, as well as the trader, and even the fuel supplier who delivers petrol or diesel to filling stations. Verification is conducted using databases, maps, satellite images, internal documents, interviews, and inspection visits to the companies' facilities. Certification is valid for 12 months. The ISCC system is now used by around 1,200 companies from 52 countries. In Germany, REDcert has overseen the certification of 1,400 biofuel operators, as well as 85 elsewhere in Europe.

High standards

According to Jörg Mühlenhoff of Germany's Renewable Energies Agency (REA), a Berlin-based think tank and advocacy group with ties to the German government and the renewable energy industry, the

"We can say that in Germany and all of Europe we use only certified biofuels. But looking at the rest of the world this is not the case"
two German programs have very high standards. "They are thorough, well-organized and trace biomass back along the entire production chain." Probably the trickiest bit, says Mühlenhoff, is the certification of foreign producers exporting to Germany, such as from Brazil. "In the end it is of course a challenge to know what's happening thousands of kilometers away from Europe," says Mühlenhoff. "But the staff of organizations such as ISCC is highly skilled and goes directly to the farmers and workers on the plantations in these countries. They do the best job possible under the circumstances."

"It's a good policy instrument," explains Jürgen Zeddies of the University of Hohenheim and author of several studies on bioenergy production. "We can say that in Germany and all of Europe we use only certified biofuels. But looking at the rest of the world this is not the case. When we ask Brazil or Argentina, for example, for certified biomass, we get it. But for domestic use or for export other than to Europe they'll use land that had been rainforest. Rainforest is still being cleared today."

For this reason, among others, environmental campaigners remain unconvinced that the current certification programs in Europe are holding bioenergy, in particular imported biofuels, to the highest standards. Biofuel production, they argue, continues to wreak havoc on tight food markets, diminish forestation, sap soil fertility, and accelerate climate change. They note that 60 percent of Germany's biomass for biofuels is imported, which is necessary in order to meet EU and domestic German targets. Domestic production alone is simply inadequate. In terms of domestic production, the primary energy crop is corn, which is among the most destructive to the soil.

"For one, the protection of human, labour and land rights is very weak or in some respects non-existent," says Reinhild Benning of Friends of the Earth Germany. Moreover, she argues, biofuel quotas cause food prices to rise by inducing farmers to swap food production for energy crops. In addition, indirect changes in land-use as a result of biofuel crop cultivation lead to higher carbon emissions because the loss of (or damage to) forest and grassland hurts carbon-absorbing ecosystems. The Commission has "refused to incorporate ILUC-factors into its criteria despite the evidence against," says Benning. ILUC is also at the centerpiece of Greenpeace's critique of bioenergy.

New methods

The stand taken by the EC's DG Energy towards ILUC originally differed from that of the more bioenergy-skeptical DG Climate.  But by the end of last year, the two DGs agreed on a compromise which is currently going through the European legislation process.  According to the Verband der Deutschen Biokraftstoffindustrie, the compromise foresees three important changes:
- ILUC factors are included in the Renewable Energy Directive, but they are included in the Fuel Quality Directive only for "reporting purposes". They do not count for compliance with the Fuel Quality Directive (i.e. with the 6% emission reduction target). A review of the reporting will take place in 2017. 
- Any kind of support for food based biofuels such as subsidies has to end in the year 2020.
- Food-based biofuels can only make up for half of the goal of ten percent renewable energies in the transport sector. By contrast, certain "second generation" biofuels can be counted multiple times in order to meet the 10 percent target.

For reporting purposes, producers of bioethanol will have to add an extra 12 gCO2 eq/MJ to their GHG-emissions if their fuel is made from starch and 13 g CO2eq/MJ if it is sugar based. Producers of biodiesel will have to add 55 g CO2eq/MJ. This would mean that ethanol could still reduce GHG-emissions, while biodiesel would emit even more GHG (107 g CO2eq/MJ) than fossil fuels (83,8 g CO2eq/MJ). Since these ILUC emissions only have to be taken into account for reporting fuel emissions, however - and not for calculating progress to a 6% GHG emission reduction target for road fuels under the Fuel Quality Directive - biodiesel, not bioethanol, is likely to remain the biofuel of choice in practice. It is cheaper, more abundant and more widely applicable (most European cars are diesel-run) than bioethanol.

In the longer term, the European Commission is aiming to phase out biofuels made from food crops altogether and to use only biofuels made from residual biomass (straw, compost), waste, and selected dedicated crops grown on surplus land that cannot be used for the cultivation of food or animal feedstock. The recent findings of a high-level group of European scientists  call for "spatial segregation

"We have no idea what the bioenergy field is going to look like in ten years. For certain though it's going to be different from the one we have right now"
of food/feed and energy producing areas by producing food on established and productive agricultural land while growing dedicated energy crops on 'surplus' land." It claims that there is untapped potential in novel kinds of crops and new production methods that could "lead to a more sustainable and efficient development of the bioenergy sector." Rather than sweeping, all-purpose criteria, the scientists prefer "regional solutions for designing and establishing sustainable bioenergy production systems." They say "we need to determine which bioenergy cultivation systems are most suitable for the respective types of surplus land taking into account yields, inputs and costs, as well as potential environmental and socio-economic impacts."

"Simply proposing the use only of residuals, like waste, and this alone is too easy," concurs Mühlenhoff of the Renewable Energy Agency, referring to environmental groups like Friends of the Earth and the Leopoldina report. "This wouldn't give us anywhere near enough biomass to make a difference."
The REA argues in a 2011 study that a more judicious selection of low-impact, high-yield energy crops, new kinds of crops, and alternative farming methods could redefine the bioenergy sector. Instead of the corn that dominates energy crops in Germany, it recommends diversifying with the likes of short-rotation woody crops, warm season grasses, cup-plant (Durchwachsene Silphie), fodder beet (Futterrübe), and wildflowers, among others. In pilot projects in some German regions experiments are being made with wildflower growth (Wildpflanzenmischungen), a seed mix of various flowers that is multi-annual, very inexpensive to produce, and requires no pesticides. The study also recommends the mixing of several crops in one field to optimize soil quality and biodiversity (intercropping), as well as the use of buffer strips, which means embordering, say, corn fields with wildflowers and other vegetation that enriches the soil and provides habitation for animal life.

But energy farmers are not yet jumping on these new ideas. "Farmers have 50 years of experience growing corn," says Mühlenhoff. "They often don't know much about these other crops or techniques yet. But they will in the not-so-distant future." Already, he notes, the German feed-in-tariff has been adapted to encourage farmers to move away from corn to other crops, like wildflower growth. "We have no idea what the bioenergy field is going to look like in ten years. For certain though it's going to be different from the one we have right now."