Framework for Transport-Related Technical and Engineering Advice and Research (PPRO 04/45/12)
Lot 2 (Road Related Technical Engineering And Advice)
Package Order Ref: 217(4/45/12)ARPS – PPRO 04/91/30
Project Sponsor: Neeraj Kaushal (DfT)
Advanced Biofuel Feedstocks –
An Assessment of Sustainability
Submitted by:
Arup URS Consortium
Lead Supplier:
E4tech (UK) Ltd
Notice
This document has been produced by the Arup URS Consortium for the Department for Transport for the above
captioned Work Package. It may not be used by any person for any other purpose other than that specified
without the express written permission of the Arup URS Consortium. Any liability arising out of use by a third
party of this document for purposes not wholly connected with the above shall be the responsibility of that
party who shall indemnify the Arup URS Consortium against all claims costs damages and losses arising.
Document History
Rev Description Originated Reviewed Date
V2.5 Final Deliverable Richard Taylor Ausilio Bauen 28/01/2014
Contents
Executive Summary ................................................................................................................................. 4
1 Introduction ..................................................................................................................................... 8
1.1 Objectives ................................................................................................................................ 9
2 Review of policy proposals ............................................................................................................ 10
3 Analysis of the multiple counting approach .................................................................................. 17
3.1 Impact of multiple counting to date ..................................................................................... 17
3.2 Future impact of proposed multiple counting ...................................................................... 23
3.3 Views on other mechanisms to incentivise advanced biofuels ............................................. 25
4 Feedstock information .................................................................................................................. 27
4.1 Feedstocks to consider in/out of scope ................................................................................ 27
4.2 Descriptive information ......................................................................................................... 29
4.3 Supply potentials ................................................................................................................... 31
4.4 Technologies .......................................................................................................................... 33
4.5 Economics .............................................................................................................................. 38
4.6 Sustainability ......................................................................................................................... 42
4.7 Direct GHG emissions ............................................................................................................ 53
4.8 Holistic view ........................................................................................................................... 60
5 Analytical framework for assessing feedstocks............................................................................. 62
5.1 Recommendations for the Annex IX lists .............................................................................. 66
Appendix A - References ....................................................................................................................... 69
Appendix B - Feedstock definitions ....................................................................................................... 76
Appendix C - Feedstock factsheets........................................................................................................ 81
List of Tables
Table 1: Comparison and amendments to Annex IX ............................................................................. 14
Table 2: Summary of RED proposals and stakeholder positions ........................................................... 16
Table 3: Summary of descriptive information ....................................................................................... 30
Table 4: Summary of feedstock supplies and biofuel production potentials........................................ 32
Table 5: Summary of feedstock prices .................................................................................................. 40
Table 6: Summary of biofuel production costs ..................................................................................... 41
Table 7: Identification of current competing uses ................................................................................ 43
Table 8: Likely replacement resources if feedstock diverted away from existing uses ........................ 47
Table 9: Summary of environmental and social factors ........................................................................ 49
Table 10: Summary of estimated price impacts .................................................................................... 52
Table 11: Summary of direct GHG emissions, assumptions and sensitivities ....................................... 57
Table 12: Summary of key criteria ......................................................................................................... 61
Table 13: Analytical framework results ................................................................................................. 68
List of Figures
Figure 1: Share of EU biodiesel consumption derived from animal fats and UCO ............................... 18
Figure 2: Share of UK biodiesel consumption derived from UCO and animal fats ............................... 19
Figure 3: UCO and Animal fat biodiesel reported under the RTFO ....................................................... 19
Figure 4: Potential conversion pathways from each Annex IX feedstock to biofuel ............................ 34
Figure 5: Current TRL status of the main conversion technologies ...................................................... 37
Figure 6: Flow diagram for the analytical framework ........................................................................... 65
Advanced Biofuel Feedstocks - An Assessment of Sustainability
4
Executive Summary
Biofuel uptake within Europe has stalled in recent years due to the policy uncertainty surrounding
Indirect Land Use Change (ILUC). Proposed changes to the Renewable Energy Directive (RED) have
gone through rounds of Commission, Parliament and Council amendments since October 2012 – with
ILUC factors, caps on food-based biofuels, multiple counting and sub-targets for advanced biofuels all
under intense debate.
Due to the lack of a clear definition for “wastes and residues” in the current RED, double counting
has to date been implemented inconsistently across Europe. A move to an inclusive list-based
approach for supporting feedstocks is therefore intended to promote greater harmonisation
between Member States. The 28 or so feedstocks within the Annex IX lists are proposed to count
double (or quadruple) towards national renewable transport targets, and/or count towards a 2020
sub-target for biofuels from novel conversion technologies using these resources. This feedstock list
started with the RED and the Commission’s communication on practical implementation, taking on-
board criteria and classifications of wastes and resides drawn up by the Renewable Fuels Regulators
Club in 2010. In their 2012 proposals, the Commission added feedstocks they considered to be low
ILUC risk, but since then several other feedstocks have been added, removed or reinserted, but with
no transparent rationale or underlying analysis. The process and criteria by which future feedstocks
will be added to the list are also still unclear.
This study provides, to the best of our knowledge, a first holistic analysis of the whole list. It gathers
consistent information and defines a rationale for including feedstocks within Annex IX using a clear
set of criteria. This evidence base will help inform the UK’s ongoing negotiations with other EU
Member States, the Department for Transport’s longer-term biofuels’ strategy, as well as the
eligibility criteria for the 2014 UK advanced biofuels demonstration competition.
Sustainability of Annex IX feedstocks
In this study, we have collected information regarding the basic characteristics, supply potentials,
technology compatibility, economics and sustainability for each of the 28 feedstocks within the
Annex IX lists. The analysis is based on the best evidence publically available that could be gathered
within the short duration of the study, and we have highlighted where the available evidence is most
uncertain and the additional information needs. For a more detailed picture, or a regional focus,
market analyses for individual feedstocks will be required. Our synthesised findings are as follows:
• Availability: Feedstock supply data for today and 2020 was collected (in million tonnes/yr
and PJ/yr of biofuel equivalent) for the UK, EU and globally. MSW and C&I wastes, straw,
manures, forestry and renewable electricity typically have the largest supply potentials.
Other feedstocks have more modest potentials, whereas wine residues, tall oil pitch, crude
glycerine resources are the most limited. Energy crops, short rotation forestry and algae will
also be in short supply by 2020, but have longer-term potential.
• Technology: There are numerous conversion technologies capable of transforming the Annex
IX feedstocks into biofuel. Many routes are still at pilot scale, whilst those in demonstration,
and hence potentially able to contribute meaningful biofuel volumes by 2020 include
lignocellulosic ethanol and butanol, pyrolysis oil upgrading, gasification routes to alcohols,
bio-Synthetic Natural Gas, Fischer-Tropsch diesel & jet, plus renewable electrolysis. Some
Advanced Biofuel Feedstocks - An Assessment of Sustainability
5
technologies are commercially available, but are only compatible with a few of the Annex IX
feedstocks, such as biomethane from anaerobic digestion (e.g. for MSW, C&I wastes), FAME
biodiesel and Hydrotreated Vegetable Oil (e.g. for UCO, animal fats and micro-algae).
• Economics: Wastes with a gate fee have a negative price, and those energy dense feedstocks
(like tall oil pitch, crude glycerine, UCO and animal fats) have the highest positive prices –
along with algae and renewable electricity. Delivered biofuel production costs have also been
calculated in the study for 30 selected supply chains.
• Competition: Competing uses vary widely, as do the likely substitute resources and price
impacts if the Annex IX feedstock was to be diverted to biofuels. Generally, feedstocks that
are disposed of (e.g. MSW, C&I wastes, UCO, waste carbon gases) or left uncollected (e.g.
straw, cobs, forest residues, small round-wood) can be collected sustainably up to certain
limits. Manure and sludge spread to land can be treated via anaerobic digestion first before
returning the digestate to land. Diverting a feedstock out of heat & power or industrial uses
will have an impact through the carbon intensity of the replacement resource (i.e. high risks
if replaced with fossil fuels vs. low risks if sustainable biomass used instead). Diverting straw
and wood from animal bedding will likely rely on additional sustainable supplies of straw and
wood to be found, whereas animal feed if diverted will need more roughage or carbohydrate
crops produced from land (a potential ILUC risk). Some industries have minimal feedstock
flexibility, such as the spirits industry (grape marcs and wine lees), paper & panel board
(forestry) and high-value chemicals (e.g. glycerine). For those feedstocks specifically grown
for biofuels, current competing uses are relatively unimportant, but the land they are grown
on is important – in particular, energy crops grown on agricultural land could cause ILUC, if
mitigation measures are not implemented. In general, those feedstocks with minimal
expansion potential and high competition levels are likely to suffer price increases if diverted
to biofuels.
• GHG savings: Most Annex IX biofuel routes are able to achieve GHG savings above 80%.
Routes using MSW, C&I waste, bagasse, wine lees, algae and waste carbon gases are more
likely to fall into the 60-80% bracket, due to cultivation emissions, chemical or energy inputs,
and transport distances. GHG emissions have been combined with the relative economics to
give an indicative cost of GHG saving (in £/tCO2e) versus a fossil comparator.
Rationale for considering feedstocks for additional policy support
Based on the gathered information, the study developed a framework to determine feedstocks for
which additional regulatory support could be justified (note that this does not specify the support
mechanism). The following hierarchy of questions are illustrated as a flow diagram that can be
followed to determine if a feedstock meets all the criteria to be eligible for support:
1. What is it classified as: a waste or processing residue (non-land using), or alternatively, an
agricultural/forestry residue, co-product or product (land using)?
2. If land using, what type of land does it come from? Has the use of high biodiversity, high
carbon stock or peat land been avoided? (meeting current RED is a minimum requirement)
3. What are the key competing uses, and potential substitute resources? Would diversion to
biofuels result in a high risk of unacceptable carbon, cost, environmental or social impacts –
Advanced Biofuel Feedstocks - An Assessment of Sustainability
6
such as the knock-on use of more fossil fuels or land? (These risks can be volume and
location dependent). Alternatively, for new non-food crops, is there a risk of competition
with food via ILUC?
4. Are the lifecycle GHG emissions savings of producing biofuel from the feedstock high enough
(versus a suitable fossil comparator) to be supported? At least 60% will be required under
the RED, but a higher threshold could be chosen by policymakers.
5. Would use of the feedstock for biofuels be economically viable without support, and hence
likely to be deployed? Or would deployment only occur with support, due to the lack of
commercial readiness of the conversion technology, infrastructure investments required or
other reasons?
Applying these criteria across the whole of the Annex IX list leads to the following conclusions:
• Several feedstocks have a significant uncollected resource that could be diverted from
current disposal, produced without indirect impacts, or sustainably extracted with limited
competition. MSW, C&I wastes, manures, forest residues, small round-wood, algae and
renewable electrolysis are likely to need further support to be economically viable or help
commercialise conversion technologies. UCO may not require additional support, depending
on infrastructure investments to access domestic supplies.
• Some feedstocks face higher levels of competition, and hence only a smaller unused fraction
of the total supply is likely to be at low risk of causing indirect impacts. This includes straw,
cobs, sewage sludge, bagasse, empty palm fruit bunches and waste carbon gases.
• For other feedstocks, such as animal fats, nut shells, husks, sawdust & cutter shavings, tall oil
pitch, brown & black liquor, support should only be provided if the industries involved can
show replacement of the missing energy demands with low carbon, sustainable alternatives
– otherwise there is a risk of increased fossil fuel use offsetting any GHG savings.
• Energy crops and short rotation forestry have longer-term potential (post 2020), but will
require strict enforcement of ILUC mitigation measures to ensure the land grown on avoids
food competition as well as being low risk (e.g. protecting carbon stocks).
• A few feedstocks should probably not be supported for biofuel production, as they have
multiple competing uses with high risks of detrimental indirect impacts – these include crude
glycerine, grape marcs and wine lees. Until more information is available for Bacteria, the
risks of its inclusion likely outweigh the benefits, as it could cover a broad range of processes
(and feedstocks).
There is significant potential for biofuel production using low ILUC risk feedstocks, as many of the
feedstocks in the Annex IX lists meet the criteria listed above – or could do so where only uncollected
fractions are considered or when fossil fuel substitution can be avoided. However, most of the novel
technologies that convert these feedstocks to biofuels still need to be commercialised, and only a
few of the routes are currently economically competitive (compared to fossil transport fuels or
conventional food-based biofuels) – despite the attractive GHG savings on offer. Ongoing European
policy negotiations regarding advanced biofuels need to base the final Annex IX lists on robust
evidence, incorporating clear guidelines and definitions, if the resulting mechanism is to support truly
sustainable biofuels – hopefully, this study is a useful tool to help move the debate in this direction.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
7
Assessment of multiple counting and other potential support mechanisms
As well as gathering information on feedstocks and developing a rationale for their inclusion within
Annex IX, we also interviewed a range of industry stakeholders regarding their views on the recent
RED proposals and the effectiveness of double counting to date. Therefore, as well as determining
what should be supported, this study has gathered some industry views on how best these
feedstocks could be supported.
Double counting under the current RED has stimulated interest in exploiting new sources of wastes
that can be processed using largely conventional technologies, with a large rise seen in the collection
and conversion of Used Cooking Oil (UCO) and animal fats into biodiesel – particularly in the UK.
Market prices of UCO and animal fats have risen sharply in recent years, incentivising collection from
new sources (with initial fraud problems now resolved), but also adversely affecting existing users.
However, there is very little evidence of the current double counting regime triggering investment in
more novel conversion technologies – it necessarily increases advanced biofuel price volatility, and
by only applying to 2020 is not being factored into high capital cost investment decisions for plants
that will take several years to construct. Many industry stakeholders stated that whilst including
multiple counting in national biofuel supply obligations would continue to support UCO and animal
fat biodiesel, further multiple counting on its own is unlikely to be an effective mechanism to achieve
uptake of more novel conversion technologies.
Several interviewees viewed a sub-target as a better mechanism for securing the deployment of
novel conversion technologies, as it would provide a more certain market demand. Targets of 0.5 -
1.5% of European transport energy were cited as being achievable by 2020 (based on technology roll-
out projections), with 2.5% seen as too high (potentially leading to non-compliance fines).
Stakeholders have said that only novel conversion technologies ought to be supported under a sub-
target (i.e. UCO and animal fat biodiesel should not qualify as ‘advanced’ biofuels). There is
recognition that there may still have to be a role for some multiple counting, in order to meet
national targets based on achievable biofuel volumes – but there is also concern by some that
excessive multiple counting (e.g. quadruple counting most feedstocks) would significantly lower the
effective energy targets and realised GHG savings.
Policy uncertainty in the EU is a major concern for industry stakeholders, and will continue to stifle
investment in novel conversion technologies unless a clear and stable framework is set out –
particularly if other world regions have more attractive policies. A strongly and repeatedly advocated
message is that biofuel (or at least renewable transport or GHG emissions reductions in transport)
targets to at least 2030 are imperative if the industry is to develop: a sub-target for 2020 is not
enough. Precise definitions, intentions and quantified objectives will also need to be established in
advance in any agreed European policy documents. However, with the ongoing negotiations (and the
possibility of last-minute compromises), there is still uncertainty regarding what will be supported,
why and how, and if and when greater policy clarity will emerge (given also the forthcoming
European Parliament elections).
Advanced Biofuel Feedstocks - An Assessment of Sustainability
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1 Introduction
The Renewable Energy Directive (RED) and Fuel Quality Directive (FQD) are the two main policies
driving biofuel deployment in the EU out to 2020. However, recent years have seen a plateau in the
consumption of biofuels, primarily due to the policy uncertainty surrounding Indirect Land Use
Change (ILUC). Proposals to amend the RED and FQD in order to address ILUC were set out in
October 2012, and since then have gone through numerous iterations and intense debate – with
various EC parliamentary committees and Member States often holding strongly different views.
Negotiations are still ongoing, with Member States heavily involved in Council discussions at the
moment. One key part of these proposals is the Annex IX list of ‘advanced’ feedstocks that would
count double or quadruple towards national renewable transport targets, or form a 2020 sub-target
for biofuels from novel conversion technologies.
This study provides, to the best of our knowledge, a first comprehensive look across the whole list,
looking to gather consistent information, improve definitions and define the rationale for the
inclusion/exclusion of feedstocks using a clear set of criteria. The rationale behind why each
feedstock deserves to be incentivised is important – and to date, a working definition and clear
framework for defining what is a truly sustainable ‘advanced’ biofuel feedstock has been missing.
As the policy situation remains fluid, being able to provide a robust evidence base regarding the
Annex IX feedstocks will enhance the UK’s understanding and positioning in its engagement with
other EU member states and institutions during the ongoing RED revision negotiations. This study
will also help inform UK discussions on post-2020 climate and energy targets within Europe, as well
as DfT thinking towards long-term decarbonisation of the transport sector.
At the same time, DfT have also been looking at measures to accelerate the UK deployment of
sustainable biofuels in the period to 2020. In August 2013, £25m of capital funding was announced
for an advanced biofuel demonstration competition, designed to underpin significant private sector
investment in one or more UK plants. E4tech and Ricardo-AEA, via the URS Arup consortia, are
currently conducting a feasibility study to report on the detailed design of the competition. This
Annex IX feedstocks project will therefore help inform some of the competition eligibility criteria and
the potential for domestic advanced biofuel deployment.
Modelling exercises by DECC, CCC and ETI have shown that sustainable biofuels are likely to play an
important part in meeting long-term UK carbon reduction targets at least cost. These biofuels are
particularly important in the near- to medium-term, as vehicle fleets and infrastructure will take
decades to transition to full electrification or a hydrogen economy. There is a strong desire to avoid a
repeat of 1G biofuel sustainability issues derailing the policy support for, and development of,
advanced biofuels – policymakers and investors want to be able to make long-term decisions, based
on robust evidence, and having carefully thought about any indirect impacts.
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1.1 Objectives
In order to address DfT’s requirements stated above, this study will therefore set out to provide the
following:
• A summary of recent EU policy developments, in order to understand the rationale behind
the current Annex IX lists, and the major changes that have been proposed.
• An assessment of the efficiency of multiple counting as an incentive mechanism for non-
food/non-land biofuels, focusing on lessons learnt from double-counting in recent years, the
likely impact of the proposed Directive double/quadruple lists on the EU biofuel industry,
and the potential for unintended consequences.
• Detailed background information on the feasibility (supply potentials), sustainability (GHG
savings, competing uses) and economic viability (prices and costs) of each of the Annex IX
feedstocks listed – plus any other feedstocks identified as missing. This will also include
qualitative information on locations and supply chains, and the commercialisation status of
suitable conversion technologies. A holistic view across the whole list will also highlight key
differences and similarities.
• An analytical framework to facilitate the objective assessment of advanced biofuel
feedstocks – both current and future – in order to define which feedstocks justify multiple
counting. This will contain a proposal for a set of criteria against which to assess the
feedstocks, which is then applied to assess the current Annex IX feedstocks in the context of
this project.
We note that every one of the 28 feedstocks considered within this study is a very complex system
(with several inter-dependencies), which makes finding ‘typical’ data, simplifying to an appropriate
level, and subsequent decision-making more challenging. However, the intention of this study is to
equip the Department for Transport, and other stakeholders, with a better understanding of the risks
and opportunities associated with each feedstock. This study is a first holistic appraisal of the Annex
IX feedstocks, but as it is based on public domain information, it is likely that in order to fully
understand the questions addressed in this study with a greater degree of confidence for a particular
feedstock, further data gathering and market analysis will be required.
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2 Review of policy proposals
In this section, we summarise the recent history of the European biofuels policy framework, focusing
on the set of Commission, Parliament and Council proposals and amendments currently under
negotiation. These key policy documents are reviewed below, highlighting any significant changes or
differences in approach relevant to advanced biofuels and feedstocks. A summary of the policy
proposals can be found in Table 2.
Interviews were also held with representatives at DfT, REA, DG Energy, DG Clima and REFUREC,
focusing on rationale behind the choice of feedstocks in each Annex IX list, to gain a better
understanding of why certain feedstocks have been supported or removed, and any underlying
analysis. The findings from these interviews have been incorporated in the sub-sections below. The
Committee on the Sustainability of Biofuels and other Bioliquids was not interviewed, as their focus
is policy implementation, not development.
The EU Renewable Energy Directive (2009/28/EC)
The RED is a common European framework intended to stimulate the production of energy from
renewable sources. It sets mandatory national targets for the overall share of energy from renewable
sources in gross final energy consumption and a minimum 10% share of renewable energy in
transport by 2020. Importantly, it also establishes sustainability criteria for biofuels that have to be
met in order for the biofuels to contribute towards national targets:
• Minimum level of GHG savings (35% today rising to 50% from 1st Jan 2017, with 60% from 1
Jan 2018 for new plants that start after 1st Jan 2017). These are to be calculated using the
energy allocation method, assigning a share of GHG emissions to any co-products in the
biofuel production process
• Land criteria (excluding land with high biodiversity value, or change of use for high carbon
stock or peat lands), with an emissions bonus for the use of restored degraded land.
The RED states that biofuels produced from waste and residues (other than those from agricultural,
aquaculture, fisheries and forestry residues) need only fulfil the minimum level of GHG savings, and
are not required to meet the land criteria set out in the RED. These feedstocks are assumed to have
zero life-cycle GHG emissions up to the point of collection. In addition, Article 21(2) of the RED states
that “the contribution made by biofuels produced from wastes, residues, non-food cellulosic material,
and ligno-cellulosic material shall be considered to be twice that made by other biofuels” for
compliance purposes towards meeting national transport targets.
Communication from the Commission on the practical implementation of the EU biofuels and
bioliquids sustainability scheme and on counting rules for biofuels (2010/C 160/02)
This communication was issued with the intent to support regulators with the implementation of the
RED. Attention is given to the double-counting of biofuels for demonstrating compliance with the
10% target for the share of energy in transport in 2020. The communication states that double-
counted biofuels include those from wastes and residues, but also that the Directive does not
contain definitions of wastes and residues. However, “waste can be understood as any substance or
Advanced Biofuel Feedstocks - An Assessment of Sustainability
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object which the holder discards or intends or is required to discard” – a definition which originates in
Article 1a of Directive 75/442/EEC on waste from 1975. Residues can include those from agriculture,
aquaculture, fisheries and forestry, as well as from processing, with the communication stating that
“A processing residue is a substance that is not the end product(s) that a production process directly
seeks to produce. It is not a primary aim of the production process and the process has not been
deliberately modified to produce it.”
Output from REFUREC working group: first list of feedstocks, along with Criteria for classification as
co-product, residue or waste
After the circulation of Communication 2010/C160/02, a working group consisting of Austrian,
Danish, Dutch, French, Swedish and UK participants to REFUREC (Renewable Fuels Regulators Club)
prepared a working document with the aim of helping Member States to implement a harmonised
classification of wastes, residues and co-products. Better feedstock definitions and clear
classifications were felt to be an important step in clarifying which feedstocks ought to qualify for
multiple counting, and how their GHG emissions should be correctly calculated under RED.
The document gives a definition of wastes and residues in line with Communication 2010/C160/02,
but clarifies that residues from agriculture, aquaculture, fishery and forestry should be those
associated with cultivation, harvest, thinning, peeling or felling. These include residues such as straw,
corncobs, bark, tops and branches. In contrast, residues from processing are those associated with
an industrial activity after collection and transport of the feedstock, for example peelings that may
occur in a food processing plant, sawdust and shavings in a wood sawmill, or empty palm fruit
bunches in a palm oil mill.
The REFUREC working group also provided a list of feedstocks, covering a range of different products,
co-products, residues and wastes – each classified in line with the definitions and considerations
from the working document. This list is incomplete, but provides useful guidance on the classification
of several food/feed “1G” crops and “advanced” biofuel feedstocks. These classifications have been
used in Table 13, with the exception of bagasse and nut shells, which the RED currently list as
agricultural residues, despite them being residues of downstream processing plants.
One disagreement between REFUREC working group members was their treatment of a 15%
threshold when determining co-products from residues. Member States that use double counting
(such as the UK) prefer to compare the material’s price to the main product price in absolute terms
(£/t), with other Member States that use tax regimes preferring to compare the material’s revenues
to the main product revenues (£/yr, i.e. value times amount). This can lead to some feedstocks being
considered a residue by some Member States, but a co-product by others. This 15% limit is seen by
some as problematic (due to fluctuations over time, complex system boundary definitions and
different levels of vertical integration across different geographies), and it has not been taken
forwards in RED or ILUC proposal discussions.
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Proposal for amendment of Directive 98/70/EC (FQD) and Directive 2009/28/EC (RED) –
Communication 2012/0288, 19th October 2012
The Commission’s proposal for amending the RED and FQD was published in October 2012, with the
aim to limit the impact of ILUC emissions from biofuels, to improve the GHG performance of biofuel
production processes, to encourage greater market penetration of advanced (“low ILUC”) biofuels,
and including a requirement to account for estimated ILUC emissions.
The proposal limits the share of energy from biofuels produced from food crops (cereals, other
starch rich crops, sugars, oil crops) to maximum 5% of the final consumption of energy in transport in
2020. It also proposes an increase in the minimum GHG savings threshold to 60% for installations in
operation after 1st July 2014, and for older installations the fuels would have to provide GHG savings
of at least 35% until 31st December 2017 and at least 50% thereafter. Since all biofuels derived from
feedstocks grown on land would now also have to account for ILUC emissions (using the values
stated in Annex V), the communication also lays out that biofuels from feedstocks that are classified
as “wastes” would have zero ILUC emissions. “Wastes” are defined as in Article 3(1) of Directive
2008/98/EC – the Waste Framework Directive, which has an explicit hierarchy for uses of waste.
The proposal to amend the RED (but not the FQD proposal) also introduces “Annex IX”, a list of
feedstocks, whose biofuels should be counted double or quadruple their energy content towards
national (RED) transport targets of member states, and gives the Commission delegated powers to
change this list as indicated by scientific and technical progress. This list contains all the materials
that were classified by the REFUREC working group as “wastes”, but also other feedstocks that were
considered by the Commission to have low ILUC risk. We spoke to one of the main individuals at the
Commission involved responsible for the drafting of this RED amendment and the Annex IX list.
As the original RED did not provide a definition of wastes and residues, individual interpretations
have led to significant differences arising between Member States regarding those biofuels that are
currently eligible (or not) for double counting – plus some Member States currently do not allow
double counting. This irregular implementation and potential for continued misunderstanding was
the reason why the Commission decided to move from generic wording to an inclusive list approach.
Introducing the Annex IX list was therefore intended to harmonise those feedstocks that received
support once the proposed amendments were implemented by each Member State, and provide
greater market clarity and uniformity. It would also highlight the broad range of feedstocks being
supported, and not just UCO and animal fats – thereby encouraging diversification of the feedstock
base. List based approaches are seen as a useful policy tool, but do require transparent ownership,
regular updating with an efficient process for including additions and sub-categories, along with clear
definitions at the appropriate levels.
Many of the Annex IX feedstocks were proposed to receive additional support, with their use for
biofuels quadruple counting, since the biofuel conversion technologies required were still to be
commercialised, and the current biofuel production costs likely to be high – these feedstocks were
also seen as having the lowest ILUC risks. Non-food cellulosic material (e.g. Miscanthus) and
Lignocellulosic materials except saw logs and veneer logs (e.g. Short Rotation Coppice, Small round-
wood) were seen by Commission individuals as being higher risk due to their use of land, hence these
feedstocks were only proposed as double counting – despite them being expensive and relying on
more novel conversion technologies. UCO and Cat I & II animal fats were maintained as only double
Advanced Biofuel Feedstocks - An Assessment of Sustainability
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counting to reflect the low cost of biofuel production based on these feedstocks, and their already
rapid uptake for commercialised biodiesel routes.
There is no additional GHG emissions saving threshold for a biofuel to qualify as advanced (beyond
the proposed 50% or 60% limits), although the Commission did indicate that their expectation is that
most of the advanced biofuels would save more than 80%. There is no single piece of analysis on the
GHG emissions of each of the Annex IX feedstocks, with only a selection of typical and default values
given in the RED for wheat straw (to ethanol), waste wood and farmed wood (to ethanol, FT diesel,
DME and methanol), along with MSW and manure (to biomethane), and waste vegetable and animal
oils (to biodiesel).
We note that no single body of scientific work or assessment framework lies behind the
establishment of this Annex IX list, the level of multiple counting, or the rationale for
inclusion/exclusion of different feedstocks. However, there is a patchwork of smaller research
assessments (some not publically available), conducted by different Member States and
consultancies, for a limited number of the feedstocks.
2012/0288(COD) - 11/09/2013 Text adopted by Parliament, 1st reading
During its first reading in the European Parliament, several key revisions were voted on and adopted:
• A minimum 7.5% share of renewable energy in petrol by 2020 in each Member State.
• The share of energy from biofuels from cereal and other starch rich crops, sugars, oil and
other energy crops grown on land is capped at 6% of final consumption of energy in
transport by 2020. This figure reflects a compromise position reached between ENVI and ITRI
committees, and would also cap land-using energy crops such as Miscanthus and Short
Rotation Coppice.
• The Annex IX feedstock list was split into Parts A, B and C, with the multiple counting
incentives altered as shown in Table 1 below.
• A sub-target for biofuels produced from more novel conversion technologies, with the final
consumption of energy in transport to be met from advanced biofuels set at 0.5% in 2016
and 2.5% in 2020. Only feedstocks in Parts A and C count towards this sub-target.
However, the ENVI rapporteur, Lepage, failed to secure a mandate to move forward into trilogue
discussions with the Council and Commission. This means a second reading in Parliament is now
required, which can only occur after the Council has reached a position. Interviewees expressed
strong doubts as to whether this can be achieved before Christmas and the impending Parliament
elections in May 2014. The view that it could be 2015 before a resolution is seen on ILUC has been
reinforced by the failed vote in the ENVI committee on 17th October 2013 – which would have tried
to fast-track a second reading by negotiating with Member States. The latest Council negotiations on
12th December 2013 have also failed to reach an agreement.
From our discussions with individuals within the Commission, it was not possible to establish the
process by which Part C feedstocks were determined and added, with most interviewees suggesting
that the Part C amendments were a success story for industry lobbying. There have been doubts
raised as to whether “Bacteria” is actually a feedstock, not a process. Carbon Capture and Utilisation
was also questioned as to whether it should be part of the RED, given the non-biogenic carbon.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
14
Table 1: Comparison and amendments to Annex IX. Parliament amendments are given in bold
Commission proposal (Oct 2012) Parliament amendments (Sep 2013)
Part A. Feedstocks whose contribution towards the
target referred to in Article 3(4) shall be considered to
be four times their energy content
Part A. Feedstocks from waste and residues whose contribution
towards the target referred to in Article 3(4) shall be considered
to be once their energy content and which contribute towards
the 2,5% target referred to in Article 3(d)(i)
(a) Algae
(b) Biomass fraction of mixed municipal waste, but not
separated household waste subject to recycling targets
under Article 11(2)(a) of Directive 2008/98/EC of the
European Parliament and of the Council of 19
November 2008 on waste and repealing certain
Directives.
(b) Biomass fraction of mixed municipal waste, but not
separated household waste subject to recycling targets or
separate collection under Article 11(1) and (2)(a) of Directive
2008/98/EC of the European Parliament and of the Council of 19
November 2008 on waste and repealing certain Directives;
derogations may be granted by Member States for separate
biowaste where processes allow the production of both
compost and biofuels.
(c) Biomass fraction of industrial waste. (c) Biodegradable fraction of industrial, retail and wholesale
waste, but not waste subject to separate collection under
Article 11(1) of Directive 2008/98/EC, and provided that the
waste hierarchy & the principle of cascading use are respected.
(d) Straw. (d) Straw.
(e) Animal manure and sewage sludge. (e) Animal manure and sewage sludge.
(f) Palm oil mill effluent and empty palm fruit
bunches.
(g) Tall oil pitch. (g) Tall oil pitch.
(h) Crude glycerine. (h) Crude glycerine.
(i) Bagasse. (i) Bagasse.
(j) Grape marcs and wine lees. (j) Grape marcs and wine lees.
(k) Nut shells. (k) Nut shells.
(l) Husks. (l) Husks.
(m) Cobs (m) Cobs
(n) Bark, branches, leaves, saw dust & cutter shavings. (n) Bark, branches, leaves, saw dust and cutter shavings.
(na) Ligno-cellulosic material except saw logs and veneer logs.
Part B. Feedstocks whose contribution towards the
target referred to in Article 3(4) shall be considered to
be twice their energy content
Part B. Feedstocks from waste and residues whose contribution
towards the target referred to in Article 3(4) shall be considered
to be twice their energy content
(a) Used cooking oil. (a) Used cooking oil.
(b) Animal fats classified as category I and II in
accordance with EC/1774/2002 laying down health
rules concerning animal by-products not intended for
human consumption.
(b) Animal fats classified as category I and II in accordance with
EC/1774/2002 laying down health rules concerning animal by-
products not intended for human consumption.
(c) Non-food cellulosic material.
(d) Ligno-cellulosic material except saw logs and
veneer logs.
Part C. Feedstocks whose contribution towards the target
referred to in Article 3(4) shall be considered to be four times
their energy content and which contribute towards the 2,5%
target referred to in Article 3(d)(i)
(a) Algae (autotrophic).
(b) Renewable liquids & gaseous fuels of non-biological origin.
(c) Carbon Capture and Utilisation for transport purposes.
(d) Bacteria.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
15
General Secretariat of the Council – 02/10/2013
The Council published its reaction on the text adopted at the first reading at the Parliament. This
suggested a higher cap of 7% for energy from biofuels produced from cereal and other starch rich
crops, sugars and oil crops. It also lowered the sub-target for biofuels produced from Part A
feedstocks in Annex IX to only 1% of final transport demand – and proposed that all biofuels from
feedstocks in Annex IX should be double-counted for their energy content. This position reflects the
lack of support for quadruple counting over the past year, plus the realisation that a sub-target
(although popular in many quarters) will be extremely challenging to meet if set as high as 2.5%,
particularly if mainly using single counting feedstocks.
The structure of the list of Annex IX feedstocks is retained from the original 2012 Commission
proposal, but a few feedstocks in Part A (now only double counting, not quadruple counting) have
been modified, or moved into Part A from Part B:
• New feedstock (ba) added: Bio-waste as defined in Article 3(4) of Directive 2008/98/EC from
private households subject to separate collection as defined in Article 3(11) of that Directive.
• Feedstock (n) definition extended: Biomass fraction of wastes and residues from forestry and
forestry related industries, i.e. bark, branches, leaves, needles, tree tops, saw dust, cutter
shavings, black liquor, brown liquor, lignin and tall oil.
• Feedstock (o) moved from Part B: Non-food cellulosic material.
• Feedstock (p) moved from Part B: Ligno-cellulosic material except saw logs and veneer logs.
• New feedstock (q) added: Renewable liquid and gaseous fuels of non-biological origin.
• We note that there is no mention of Bacteria or Carbon Capture and Utilisation in these
Council positions, and that Algae remains unchanged as feedstock (a) in Part A.
Interestingly, although energy crops (e.g. Miscanthus, Short Rotation Coppice) were dropped from
Annex IX in the Parliament amendments and capped alongside food crops, they have been reinstated
to Annex IX in this Council reaction and are not proposed to be limited under the food cap. UCO and
animal fats have retained their usual position of continued double counting towards the 10%
transport target, but not contributing towards any sub-target or food cap.
The Presidency has been very active in trying to reach a compromise position, with several meetings
of the ILUC Working Group in recent weeks. The very latest Council position (3rd December 2013)
actually has no Europe-wide sub-target for advanced biofuels, since many Member States (including
the UK) are concerned that there is no guarantee that a specific target could be reached – instead,
the possibility of a voluntary target at the discretion of Member States has been suggested. This
latest position also has double counting of Part A feedstocks in Annex IX (i.e. not UCO and animal
fats) towards both 10% transport and overall renewable energy targets. There has also been support
for x5 counting for electric road vehicles and 2.5x for electric rail.
COREPER (Committee of Permanent Representatives) met on 14th November and is meeting again on
29th November, ahead of the Energy and Environment Councils on 12/13th December. It would still be
possible for the Council to reach a political agreement in December, but as highlighted above,
interviewees see it being very tight as to whether there would be sufficient time to then get through
the full procedures with the European Parliament, ahead of the Parliament elections in May 2014.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
16
Table 2: Summary of RED proposals and stakeholder positions
Policy scenario 2020
Food cap
2020
Sub-target Single counting Double counting Quadruple counting
Existing RED No No Several advanced feedstocks not
recognised for double counting by MSs
“Wastes, residues, non-food cellulosic material, ligno-
cellulosic material” – different interpretations in MSs None
Commission
Proposal,
Oct 2012
5% No None of the Annex IX feedstocks
proposed to single count
UCO, Category I & II animal fats, non-food cellulosic
material, LC material except saw logs and veneer logs
Algae, bio-MSW, industrial bio-waste, straw,
animal manure & sewage sludge, POME &
EPFBs, tall oil pitch, crude glycerine, bagasse,
grape marcs & wine lees, nut shells, husks,
cobs, bark, branches, leaves, saw dust &
cutter shavings
Parliament
Amendments,
Sep 2013
6%
2.5%
(with 0.5% in
2016)
Bio-MSW, industrial bio-waste, straw,
animal manure & sewage sludge, tall oil
pitch, crude glycerine, bagasse, grape
marcs & wine lees, nut shells, husks,
cobs, bark, branches, leaves, saw dust &
cutter shavings, LC material except logs.
These contribute to the sub-target
UCO, Cat I & II animal fats. These do NOT contribute to the
sub-target, only 2x counting towards the 10% transport
target
Algae, Renewable liquids & gaseous fuels of
non-biological origin, Carbon Capture &
Utilisation for transport purposes, Bacteria.
As well as contributing to the sub-target,
assumed also to count 4x towards sub-target
Council Response,
Oct-Dec 2013 7%
Was initially 1%
Latest
compromise is
to be at MS
discretion
None of the Annex IX feedstocks
proposed to single count
Algae, bio-MSW, separately collected bio-MSW, industrial
bio-waste, straw, animal manure & sewage sludge, POME
& EPFBs, tall oil pitch, crude glycerine, bagasse, grape
marcs & wine lees, nut shells, husks, cobs, bark, branches,
leaves, needles, tree tops, saw dust, cutter shavings, black
& brown liquor, lignin & tall oil, non-food cellulosic
material, LC material, Renewable fuels of non-bio origin.
These contribute to the sub-target, and count 2x to the
sub-target, 10% transport AND overall renewables targets
UCO, Cat I & II animal fats. These do NOT contribute to the
sub-target, only 2x counting towards 10% transport target
None of the Annex IX feedstocks proposed to
quadruple count
UK REA position,
Feb 2013 No
2%
only using novel
conversion
technologies
Algae, bio-MSW, industrial bio-waste,
straw, animal manure & sewage sludge,
POME & EPFBs, tall oil pitch, crude
glycerine, bagasse, grape marcs & wine
lees, nut shells, husks, cobs, bark,
branches, leaves, saw dust & cutter
shavings. These contribute to the sub-
target - assumed non-food cellulosic &
LC material except logs would as well
UCO, Cat I & II animal fats. These do NOT contribute to the
sub-target, only 2x counting towards the 10% transport
target
None of the Annex IX feedstocks proposed to
quadruple count
Light blue text reflects commentary on whether feedstocks count towards any sub-target, whereas text in black are just the feedstocks assigned to each multiple counting category
MS = Member State. LC = Lignocellulosic. MSW = Municipal Solid Waste. POME = Palm oil mill effluent. EPFB = Empty palm fruit bunches. UCO = Used Cooking Oil. Cat I & II = category 1 and 2.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
17
3 Analysis of the multiple counting approach
In this section, we review the efficacy of the multiple-counting mechanism as an incentive for the
uptake of advanced biofuels. The review comprised a series of interviews with biofuel industry
stakeholders, along with insights gained from relevant literature and market data. The goal of the
exercise is to establish the past and current impacts of multiple-counting (drawing on experiences to
date), and to understand the future potential of the proposed multiple-counting to 2020. We also
engaged interviewees on the topic of % sub-targets for biofuels produced from novel conversion
technologies and other support mechanisms. Interviews were based around the following topics:
• The impact of double-counting to date, including stimulation of investment, uptake of new
routes, and GHG savings.
• Lessons learnt and negative impacts, including emergence of unintended consequences (e.g.
fraud), or differences in policy implementation between Member States.
• Whether proposed double or quadruple counting in the RED will be effective in stimulating
investment in advanced biofuel technologies and increasing deployment, and whether any
foreseeable unwanted effects will arise.
• The effectiveness of a proposed 2.5% sub-target for biofuels from novel conversion
technologies, and whether the target is achievable.
• The role of other policy mechanisms, including the setting of targets and a policy framework
to 2030.
In total we spoke with representatives from six organisations (fuel companies, biofuel producers and
traders, trade associations) with interests in advanced biofuels, capturing a diverse range of views on
the role of multiple counting and the best policies for incentivising advanced biofuels in the EU.
3.1 Impact of multiple counting to date
Double counting incentives have been transposed into national renewable energy obligations by
several Member States (but not all), and with considerable variation regarding the eligibility of
particular wastes and residues. For example, UCO does not count double in Denmark, and animal fats
do not count double in Germany. Some countries lacking double counting regulations all together
(e.g. Poland), or cap the amount of double counting material (e.g. France). There is also no
harmonised implementation regarding control mechanisms, verification and documentation
requirements – Italy only accepts EU feedstocks, Dutch and German verification requirements are
particularly strict, and France requires every production site to be registered.
Individual Member States are responsible for implementation of the RED and FQD, but there exist
significant variances in compliance mechanisms – for example, the UK is volume based, most other
EU countries use an energy basis, whilst Germany is expected to switch to a GHG basis in 2015. Many
member states have annual targets, but others only have interim targets at specific years. Some
mandate ethanol and bio-diesel separately, whilst others only mandate the total level of biofuel use
(as in the UK). And some member states have not yet permitted the use of certain fuels counting
towards their quota obligations (e.g. butanol is only allowed in a handful of countries). The policy
picture in Europe is therefore highly fragmented – hence including or excluding certain ‘advanced’
feedstocks from a multiple counting list might not end up being adopted by a majority of Member
Advanced Biofuel Feedstocks - An Assessment of Sustainability
18
States in a timely or consistent manner, unless the rules are very clear, definitions leave minimal
room for interpretation, and the policy is rigorously enforced.
UCO and Animal fats
All of those interviewed upheld the view that the double-counting incentive has contributed to the
uptake of UCO and animal fats as biofuel feedstocks in the EU. Evidence of this can be seen in Figure
1, in particular for UCO, whose share of the EU biodiesel feedstock base has grown significantly since
2010 – the date at which double counting began to be transposed into legislation by Member States.
Focusing on the UK, there is also reason to believe double counting has been responsible for an
increased contribution from UCO and animal fats. While the animal fat share of the biodiesel
feedstock base has dropped since 2010, higher volumes of category 1 animal fats (eligible for double
counting) now feature (Ecofys, 2013). The drop in % share can be partly explained by the shifting
preference of fuel producers towards lower-cost UCO which has flooded the market since being
incentivised. The UCOME share of UK biodiesel has increased significantly, although this is in part due
to the duty differential introduced for UCO biodiesel between April 2010 and April 2012 (RTFO Years
3 and 4). However as shown in Figure 2, the UCOME share remains high now even though the duty
incentive has been removed.
It should be noted however that the volumes of UCOME have dropped significantly between Year 4
and 5 with the removal of the duty incentive (see Figure 3). Year 5 was also the first full period in
which double counting applied, hence it makes sense that actual volumes would drop significantly if
all of this UCOME now double counts towards the target – fuel blenders suddenly needed to buy half
of the previous year’s UCOME volumes in order to comply. However, comparing Year 2 (09/10) with
Year 5 (12/13) – both years without the duty differential – UCOME volumes have still risen from 43
million litres (4% of biodiesel feedstock base) to almost 400 million litres (~80%), indicating that
double counting has encouraged greater volumes of biofuels produced from wastes to be consumed
in the UK.
Figure 1: Share of EU biodiesel consumption derived from animal fats and UCO (USDA, 2013)
Advanced Biofuel Feedstocks - An Assessment of Sustainability
19
Figure 2: Share of UK biodiesel consumption derived from UCO and animal fats (DfT, 2013)
Figure 3: UCO and Animal fat biodiesel reported under the RTFO (DfT, as of 7th
Nov 2013)
Several of those interviewed believed that the double counting mechanism has to some degree
incentivised investment in processing facilities for UCO and animal fat feedstocks. One industry
player very much welcomed the original double counting mechanism from a commercial perspective
and asserted that countries which transposed double counting into national biofuel schemes were
seen as attractive for investments in plants processing UCO and animal fats.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
20
Investment Uncertainty
All interviewees expressed the view that to date, there is very little evidence of double counting
triggering investment in more novel technologies to develop advanced biofuel feedstocks (other than
UCO and animal fats which use conventional biodiesel technology). Considerable doubt was
expressed that the double counting mechanism constituted a major trigger for investment for the
few cases in Europe where such investments have been made in novel demonstration plants (e.g.
Italy, Germany and Denmark).
The argument was made by several stakeholders that multiple counting cannot be reliably factored
in when making investment decisions on novel technologies because of the difficulty in estimating
the economic value (additional revenues) that multiple-counting creates. The value of a double-
counting biofuel depends on the price of the fossil fuel baseline and the price of other competing
biofuels, both of which can be highly variable. In principle the value of the double-counting fuel is
two times the price premium of a conventional biofuel over the fossil fuel. Any volatility in the prices
of fossil fuel or conventional biofuel will be amplified in the advanced biofuel price – e.g. if the fossil
fuel price rises $0.1/gal and conventional biofuel prices fall $0.1/gal, then the advanced biofuel price
could fall by $0.4/gal. According to most interviewees, the value of the double-counting biofuel is
therefore too uncertain to justify the investments necessary to bridge the ‘valley of death’ towards
commercialisation of novel technology routes.
The point was also made that double counting only applies until 2020 and would thus only provide a
maximum of 3 years of support to plants operational in 2017 (the earliest possible start date for a
first of a kind commercial BTL or lignocellulosic ethanol plant). These 3 years of support are unlikely
to make a significant difference to the rate of return for a plant with a lifetime of 20 years or more.
A lack of progress in demonstrating technologies at scale (e.g. BTL, lignocellulosic ethanol) has also
played a major role in holding up investments, as has the general economic environment and lack of
availability of finance for riskier projects. Thus it may not be fair to judge multiple counting as an
entirely ineffective mechanism per se – although it has failed to outweigh these other difficulties.
Further discussion of the impact of policy uncertainty on investor confidence, and the lack of recent
deployment, is given in Agra CEAS (2013).
Market Prices
An assessment of commodity prices indicates that double counting has had a marked impact on
market prices of certain biofuels and feedstocks. Prices for UCO and animal fats have increased in
recent years as different Member States introduced double counting, changed regulations, tightened
certification and also started importing feedstocks to meet demands (Greenea, 2011).
From Platts (July 2013), fossil diesel was trading in Europe at ~$2.9/gal ($21/GJ), vegetable oil FAME
at ~$3.7/gal ($29/GJ), and UCO FAME at ~$4.7/gal ($37/GJ). Vegetable oil FAME has therefore been
trading at a $0.8/gal ($8/GJ) premium to fossil diesel, and UCO FAME trading at a ~$1.6/gal ($16/GJ)
premium. The market for UCO FAME has therefore reached its maximum price premium over
vegetable oil FAME, trading at a fully double-counted price. This reflects the fact that UCO FAME is
twice as valuable as vegetable oil FAME to blenders in meeting their obligations (since they need only
half the volume to comply).
Advanced Biofuel Feedstocks - An Assessment of Sustainability
21
Given the low cost of biodiesel conversion, a similar premium can also be seen with feedstock prices
(UCO is currently trading around $980-1100/t, compared to vegetable oil at $830-1010/t). However,
as recently as 2009 before double counting was introduced, UCO was trading at $400-600/t, a 25-
50% discount on virgin vegetable oils (REFUREC working group, 2011) – but UCO now trades at a 5-
20% premium (STX Services, 2013; Platts, 2013). Double counting has therefore had a marked impact
on UCO and animal fat feedstock prices in Europe – and whilst the policy may be inefficiently
providing large rents for some supply chain actors (given the low risk and commercially available
technologies involved), UCO and animal fats do still provide very significant GHG savings. Whilst
there could have been UCO and animal fats converted to biodiesel had double counting not existed
(since the feedstocks were cheaper than virgin oils in the past), double counting has been effective in
overcoming the barriers of establishing collection infrastructure and adding purification pre-
processing (total FAME conversion costs using UCO are about twice those of a plant using virgin oils).
Greenea stated in Nov 2011 that “As the supply is more or less flat, markets with lower value such as
incineration and combustion are losing this feedstock. The competition between buyers is abundantly
clear from the increasing pressure put on governments to withdraw tallow from the definition of
wastes, which is largely left open for the member states’ interpretation by the article 21 of RED”.
They also mention that “The pressure on TME is particularly high because the oleo chemical industry
does not accept the sudden rise in prices tallow has experienced since France and the Netherlands
have implemented double-counting schemes.”
Negative Consequences
Undoubtedly there have been some negative consequences with the implementation of double
counting. The main issues that were highlighted by interviewees are outlined below:
• Fraud: stakeholders pointed towards evidence of fraud in reporting of volumes of UCO, and
the perverse incentive created for artificially increasing the volumes of UCO in the market
(faster use and recycling of cooking oil to make larger profits, thereby demanding more virgin
oils, and potentially causing ILUC). Most respondents felt that with stringent chain of custody
rules these problems would be addressable, and this has already started to happen in places
such as the UK. However, some respondents identified the additional cost of such
certification as an unfair penalty to impose solely on wastes and residues, and they
advocated applying the same chain of custody procedures to all biofuels (in order to also
reduce the risk of fraud and unsustainable practices in agricultural product supply chains).
Several stakeholders stressed the importance of agreeing on clear certification rules which
should apply to all Member States in advance of implementation, but acknowledged the
difficulty in securing agreement between all countries.
• Market distortions: the fact that only some Member States have implemented double
counting measures in their biofuels policy, with varying definitions of which feedstocks are
eligible and the required levels of certification, has produced a varied price structure for
advanced biofuels across the EU. Volatile prices have also been seen during double counting
implementation as demands shifted between Member States. A continued lack of
harmonisation makes the price of advanced biofuels more unpredictable (harder to invest
in), and can reduce overall GHG savings due to feedstocks or biofuels being transported
longer distances in order to reach more attractive markets found in particular countries
(rather than being used locally). DG ENER (2013) state that “fragmentation throughout the
Advanced Biofuel Feedstocks - An Assessment of Sustainability
22
EU is counterproductive. It is more efficient and effective to focus efforts of the stakeholders
towards a limited number of blending options.”
• Impacts on other industries: it was asserted by one stakeholder that other industries which
use the same wastes and residues have been disadvantaged as a result of double counting
incentives. The example of animal fats as used by the oleochemicals industry was given, with
evidence that growing demand from the biodiesel sector in Europe has pushed the price of
the material up (ICIS, 2012).
Objectives of Multiple Counting
An assessment of the effectiveness of any mechanism requires an understanding of what its
objective is. Opinions of the efficacy of multiple counting to date diverge in the industry partly
because there is no common understanding of the objective of multiple counting.
The European renewable ethanol industry representative, ePURE, in a study on the effectiveness of
the double counting measure (ePURE, 2013) stated that the objective of double counting is “to bring
advanced biofuels onto the market which will result in diversification of the raw materials used as
well as technological innovation.” The emphasis here on technological innovation mirrors the
definition of an ‘advanced biofuel’ set out by the UK Renewable Energy Association and several
agricultural industry bodies in a joint position paper (REA et al., 2013) where they define advanced
biofuels as using “advanced processing and conversion technologies.”
In contrast, the European Biodiesel Board in their 2013 position paper adopt the definition from the
European Sustainable Biofuels Forum, which does not place an emphasis on advancing innovative
technologies – hence they consider UCO and animal fat FAME to be ‘advanced’ biofuels.
Although the role of multiple-counting in bringing forward new technologies is not explicitly laid out
in the RED, the Directive implies that the mechanism is intended to be used to encourage research
and development in such technologies. Recital 89 states “Member States may encourage the use of
biofuels which give additional benefits of diversification (...), by taking due account of the different
costs of producing energy from traditional biofuels on the one hand, and of those biofuels that give
additional benefits on the other. Member States may encourage investment in research and
development in relation to those and other renewable energy technologies that need time to become
competitive.”
However, the implemented RED and the recent proposed amendment texts do not state what the
intended impact of multiple counting is on expected volumes of any new technologies – there is no
sensitivity analysis or forecast of volumes with and without various levels of multiple counting. This
use of qualitative objectives (diversification of feedstock base, use of wastes and residues, not yet
competitive) and lack of quantitative “success” targets therefore makes it difficult to give a definitive
assessment of effectiveness of multiple counting thus far. Attempting any assessments of policy
effectiveness in the future will also be challenging if there is no common understanding reached on
the objectives of the policy.
Based on our interviews with European policymakers detailed in Section 2, we believe that the main
objective of multiple counting, and purpose behind the Annex IX lists, was to stimulate the uptake of
more sustainable feedstocks. By conducting this study, we are helping to check that these feedstocks
have a significant potential, with a low risk of unintended consequences, with likely routes to biofuel
having high GHG savings but still requiring economic or deployment support.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
23
3.2 Future impact of proposed multiple counting
Biofuels from novel conversion technologies
Several interviewees acknowledged the general message of support for novel conversion
technologies (i.e. excluding UCO and animal fat biodiesel) which the proposed multiple counting
proposals send out. However, concerns were expressed by several stakeholders that multiple
counting is not the most effective mechanism with which to achieve uptake of more novel
conversion technologies and the feedstocks which they utilise. Many stakeholders remarked on the
lower effective biofuel policy target which multiple-counting introduces, since only half (or quarter)
of the volumes are required in the market, compromising on GHG savings and fuel security.
Most stakeholders agreed that in the absence of other measures, multiple counting would to some
extent help increase European consumption of biofuels from novel conversion technologies.
However, in the absence of any other mechanisms (such as a food cap, sub-target for novel routes,
2030 biofuels target, loan guarantees), none of the interviewees believed that a multiple counting
mechanism on its own would be sufficient to drive investment in European biofuel plants utilising
novel conversion technologies. In other words, whilst double counting is unlikely to support EU
production, it could incentivise imports from other regions and their consumption within the EU.
Several interviewees see the US as a more appealing market for deployment of innovative conversion
technologies (see Section 3.3 for further discussion), and stated that the biofuels produced could be
exported to the EU if attractive.
Several stakeholders advocated a need for simple policies, and multiple-counting was identified by
some as a complicated policy which may need to be revised and adapted in the future (damaging
investor confidence). One stakeholder suggested that multiple counting could be made more
attractive if attached to a price floor or “contracts-for-difference” mechanism, thereby ensuring
greater certainty for investors, but these more complex options have not been widely discussed or
advocated by industry or policymakers yet.
One stakeholder criticised the absence of a clear means to introduce new feedstocks to the Annex IX
lists and believed that if there remained no scope for this, the policy would not be effective at
bringing forward novel technologies. It was argued that if the multiple-counting lists remain, there
needs to be objective qualifying criteria for adding new feedstocks so as not to exclude promising
biofuel pathways in the future.
Another stakeholder commented that the lack of replication of double counting in the FQD and the
overall renewables target imposes additional requirements on fuel suppliers and the heat and power
sectors in order to meet the overall 2020 target. The stakeholder‘s view was that if multiple counting
continues there should be harmonisation between the various mandates to address this.
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UCO and Animal fats
All respondents believed that multiple-counting would continue to benefit UCO and animal fats. One
respondent expressed that view that double counting should be discontinued for UCO and animal
fats as public funds should be used to promote new, more expensive, conversion technologies and
widen the feedstock base. Others expressed the view that removing support for UCO and animal fats
would devastate these industries and further undermine investor confidence in the biofuels industry,
and that support should remain since these feedstocks deliver material GHG savings (plus further
infrastructure investment is required if significant household supplies are to be accessed).
Quadruple counting
Nearly all stakeholders responded negatively to the concept of quadruple counting. The following
shortcomings of this incentive were identified:
• Given the uncertainty over the economic value of quadruple counting (and its duration) this
approach will not give investors the certainty they need to back novel conversion
technologies, especially those with high capital cost requirements – and therefore will not be
successful in kick-starting the industry.
• Quadruple counting is excessive and will compromise on carbon savings – biofuels derived
from these feedstocks which achieve an 80% reduction in GHG intensity over the fossil fuel
comparator are in reality only contributing a 20% reduction within the context of the overall
target. Respondents felt that overall this would lead to lower carbon savings in 2020, thus
undermining the whole initiative. One respondent suggested that multiple counting could
only be justified if it incentivised the highest carbon saving fuels in a proportional manner
(i.e. only very high carbon saving fuels would count quadruple). We note that, from 2015,
Germany will be adopting a similar GHG savings basis for measuring compliance with their
national mandate (switching from using an energy basis).
• By the same token, some respondents expressed concerns that quadruple counting could
actually reduce the volumes of biofuels deployed from novel conversion technologies,
compared to having no quadruple counting, since this potentially could result in a previously
achievable policy target being lowered.
• Based on the experience to date with double counting, it is likely that the quadruple counting
mechanism could introduce further market distortions and inefficiencies if not implemented
uniformly across all Member States, and have too high a risk of perverse incentives being
established (as well as a high risk of fraud).
Overall view on multiple counting
While responses to multiple counting were mixed overall, shortcomings of the approach were
highlighted by all respondents. The prevailing view was that multiple counting alone will not prove
effective in stimulating a material uptake of biofuels produced using novel conversion technologies.
The lack of economic dependability was identified by most of those interviewed as the biggest
concern with this approach, and all identified alternative or complementary measures which would
better address the lack of investment in novel conversion technologies.
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3.3 Views on other mechanisms to incentivise advanced biofuels
Sub-target for novel conversion technologies
Several respondents viewed sub-targets as a better mechanism for securing the deployment of novel
conversion technologies than multiple counting. It was generally viewed as providing more investor
certainty than multiple counting, since it guarantees a market demand. Feedback on the food cap
was mixed. It was generally held that a food cap would provide a price premium to advanced biofuels
(since it implicitly requires greater advanced biofuel deployment), but several stakeholders voiced
concerns that it would undermine investor confidence in the biofuel industry as a whole.
We did not specifically set out to ask stakeholders for their views on which combinations of policy
mechanisms could potentially be most effective, although a few interviewees did highlight concerns
that introducing multiple counting within a sub-target for novel conversion technologies would
reduce the effectiveness of the sub-target, because of reduced biofuel volumes and GHG savings.
Responses regarding the size of the sub-target were mixed. All interviewees were uncertain about
what sub-target could realistically be achieved, but nearly all believed 2.5% to be too high, especially
if it does not encompass the contribution from UCO and animal fats or does not allow multiple
counting within the sub-target. Figures of 1.5%, 2% and 3% were cited as maximum achievable
penetrations if all waste feedstocks are included, while 0.5%, 1% and 1.5% were cited as achievable if
UCO and animal fats were not included. We note that the REA advocates a 2% target for novel
conversion technologies (i.e. without UCO and animal fats) with only single counting applying within
the sub-target, which appears challenging based on these interviewee estimates.
Two respondents welcomed the high targets, believing that it would increase the value of biofuels
from novel conversion technologies. Other respondents expressed concern that an excessively high
target would impose high fines on suppliers if they are unable to meet the 2020 mandate. The risk to
the UK was highlighted – a lack of local production would expose the UK to fines or high import costs,
which would almost certainly be passed on to consumers. One source believed that introducing
alternative ways to meet the target would ease this risk (e.g. greater contribution from high GHG
saving 1G biofuels, contributions from EVs etc.).
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General policy messages
Several policy messages emerged consistently throughout the interviewees:
• A policy framework to 2030 and beyond is imperative. Biofuel targets for 2030 were strongly
advocated, but at the very least a renewable transport target for 2030 is required, in order to
provide clarity to the investment community that the output of biofuel plants using novel
conversion technologies will be advantaged for a significant proportion of their lifetime
(often 20-30 years). Given construction timelines for commercial scale plants (typically 2-4
years), having targets for only 2020 is far too close to make a meaningful difference to plant
economics and hence investment decisions. However, the EU policy picture beyond 2020 still
remains uncertain, with GHG and/or energy targets yet to be agreed for 2030.
• Policy uncertainty in the EU is a major cause for concern, particularly for those with interests
in novel routes. There is evidence that the protracted ILUC debate has stifled investment
over the last few years, in both conventional and advanced biofuel sectors. Stable and
transparent policies which minimise the need for revision were advocated by almost
everyone. DG ENER (2013) state that “A stable market outlook – until 2020 and beyond – is a
crucial condition for stakeholders to invest in the developments needed for the various
marketing options. Stable, effective and longer-term biofuel strategies and policies, both on
EU and Member State level, are conditions for successful implementation”
• The US is currently a more attractive place than the EU to invest in the development of
novel conversion plants. Stakeholders believe that there is more policy certainty and clarity,
as well as financial support, in the US:
o Clear carve-outs for ligno-cellulosic ethanol and ‘advanced’ (sugarcane ethanol)
biofuels which deliver high GHG savings
o Generous grants offered by the Department of Energy
o Access to loan guarantees with attractive terms
o Supply-side incentives (e.g. Biomass Crop Assistance Program)
• Clear criteria should be set out for the definition of an ‘advanced’ biofuel which would
determine whether or not particular feedstocks are eligible to be multiple counted or
contribute to a sub-target. There was some disagreement over what the criteria should be.
While all agreed that the general sustainability and GHG savings delivered by the biofuel are
important, there was disagreement over whether the definition of ‘advanced’ should require
the fuel to be derived through ‘advanced’ processing technologies and thus incentivise novel
conversion technologies – or whether FAME biodiesel from UCO and animal fats should
continue being classified as ‘advanced’.
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4 Feedstock information
4.1 Feedstocks to consider in/out of scope
From an assessment of the REFUREC working group lists, RED policy proposals and stakeholder
interviews, we identified a small selection of feedstocks that deserve further discussion in the
context of this study’s scope. Some of these feedstocks could potentially be deemed as missing from
the proposed Annex IX lists, or worthy of forming a feedstock sub-category. Some of these
feedstocks appear not to have been considered in the drafting of Annex IX, whilst others were
excluded on purpose (and should not be included in Annex IX). We discuss these feedstocks in the
context of this study’s scope below:
• Crude tall oil. This is a refining feedstock for the production of fatty acids, rosins and sterols,
with Tall oil pitch a distillation by-product (already listed separately). The Commission
considered crude tall oil to be too valuable, and hence removed it from their lists to avoid
what were seen as obvious displacement risks. We note that the latest Council response lists
“tall oil”, which may therefore re-include this feedstock.
• Black & brown liquor. Similar to crude tall oil, the Commission suggested that because of the
value of soapy black liquor in relation to producing crude tall oil and recycling chemicals
within the mill, it had been excluded. Whilst this feedstock was missing from the Oct 2012
Commission lists, during the course of the study, the Council included black & brown liquors
within their Oct 2013 response. We have therefore assessed black & brown liquors in this
study, and note that it is possible to produce biofuels whilst recycling the required chemicals.
• Category III animal fats. Given these are the least contaminated of the animal fats, and
contain many sub-categories that are fit for human (and livestock) consumption, Category III
animal fats were removed from the Commission lists to avoid food competition.
• Small round-wood/pulp-wood: The Commission excluded high value wood (saw logs and
veneer logs) from Annex IX, as they did not wish to promote deforestation or their use in the
lower value energy sector. However, they had not thought beyond large logs to potentially
excluding small round-wood/pulp-wood, due to a lack of information at the time – hence
these smaller trees are still currently allowable under the proposed “Ligno-cellulosic material
except saw logs and veneer logs”.
• Sugarcane trash. A potentially large uncollected resource (especially with the move to ban
in-field burning in Brazil), but subject to sustainable extraction limits. However, within Annex
IX this trash resource would likely be covered under the broad description of “Straw” as a
feedstock, and hence will not require separate analysis.
• Bark, branches and leaves. Bark is currently placed together with forestry residues – but one
stakeholder has noted that this is relevant only if debarking is immediately after felling and
before forwarding the timber. Today, this practice is very rare - in normal forestry
operations, bark arises as a processing residue from debarking inside pulp-mills and saw
mills. Therefore, logically bark should be grouped together with saw dust & cutter shavings,
instead of with branches and leaves. However, since all the RED proposals list bark, branches
and leaves together, we also retain this structure for consistency.
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• Olive pits. Along with a range of other high energy content agricultural residues recently
used for biomass co-firing in power stations, this resource could likely be covered under a
wider definition of Husks.
• Bio-waste as defined in Article 3(4) of Directive 2008/98/EC from private households
subject to separate collection as defined in Article 3(11) of that Directive. We note that this
feedstock has not been separately considered in this study, as it was only proposed for
separate consideration by the Council in November after our study analysis was complete.
This resource is therefore simply included within the bio-fraction of MSW feedstock
alongside the other MSW streams, and not considered separately.
• Carbon Capture and Utilisation (CCU) for transport purposes. There are several different
methods of capturing carbon that could be interpreted to fall within this description.
Lanzatech is actively developing a syngas fermentation technology for producing ethanol
from steel mill basic oxygen furnace (BOF) gases, i.e. a mix of gases with up to about two
thirds carbon monoxide. We are therefore assuming in the context of this study (with its
2020 focus), that CCU is only likely to describe these steel mill “waste carbon gases”. Other
carbon gases, such as CO2 streams from power stations, could be captured in large volumes
by 2020 depending on the development of CCS demonstration projects. However, the
technologies to then convert these CO2 streams into a transport fuel are at a low level of
commercialisation, hence these CO2 streams will not be a relevant transport feedstock in the
2020 timeframe, and are ignored in our resource assessment. There has been debate
regarding whether CCU is permissible as a “biofuel” under the RED, given the fossil carbon
being used. There would need to be close attention paid to the fact that the producer of the
carbon-rich feedstock gas still needs to account for fossil GHG emissions to atmosphere –
since e.g. the steel mill and the biofuel producer cannot both claim they are zero carbon.
• Renewable liquid and gaseous fuels of non-biological origin. Similarly, there are numerous
materials that could fall under this description. However, producing hydrogen for transport
via renewable electrolysis of water is the only likely fuel pathway to be developed at scale by
2020 – i.e. renewable electricity is the “feedstock” considered in this study. We note that this
feedstock is for input into renewable electrolysis – it is not for use directly in battery electric
vehicles (out of scope of this study). Other options to keep a watching brief over, but at a
lower level of commercialisation, are methods of synthesising long-chain hydrocarbons
directly from a combination of atmospheric CO2 and renewable electrolysis hydrogen.
• Bacteria. It is very unclear as to what “Bacteria” is actually meant to encompass, and
whether it is actually a process, not a feedstock. Known metabolic pathways have to rely on a
source of carbon atoms (e.g. sugars) in order to produce a fuel – or if instead using
atmospheric CO2, they require an energy source (e.g. sunlight, electricity, iron, sulphur,
ammonia). There is no definition available or any further information regarding potential
project developers looking to produce biofuel from this route (and no obvious match in the
public domain, as is the case with Lanzatech and “Carbon Capture and Utilisation”). None of
our interviewees were able to provide further insight. We therefore judge that this category
is both unlikely to produce commercial quantities of fuel by 2020, and given the uncertainty
(and bacterial options that use sugars) its inclusion in the Annex IX list presents a higher risk
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than excluding it for the time being. It could however potentially be included in the future
once more information becomes available.
In its October 2012 ILUC proposals, the Commission provided short definitions for some of the Annex
IX feedstocks (either in Annex IX or upfront in the Recitals), but many are missing, unclear or
potentially overlapping. Discussions are ongoing on firming up these definitions, however, there is
not yet a single definitions document being pulled together for this purpose. Apparently, this is only
likely to happen once (or if) the lists are agreed upon, along with confirmation of any sub-target for
novel conversion technologies, a food cap and the multiple counting levels. Terms are starting to be
included in the Council draftings, but it will ultimately be down to the Presidency as to what gets
added to the latest drafts. There is recognition that to have any real impact, these definitions will
need to be provided (and confirmed) before any Directive amendment gets passed into law – there
may therefore only be a limited window of opportunity between final consensus and voting.
In Appendix B, we provide our latest understanding of the feedstock definitions, highlighting any
particular points of contention or uncertainty. Over the course of the analysis we split several of the
“feedstock” groups into more useful sub-categories, given the different physical and economic
characteristics requiring disaggregation. For example, “animal manures & sewage sludge” naturally
splits into two sub-categories, “animal manures” and “sewage sludge”. A full list of sub-categories
analysed is given in Appendix C. For those feedstocks selected for analysis, we collected descriptive,
supply, technical, sustainability and economic information as summarised in the sections below.
4.2 Descriptive information
We have collected information from numerous public sources regarding the following basic
qualitative information for each feedstock:
• Definition (summarised in Appendix B), and classification as given by the 6 participants in the
REFUREC working group
• Typical moisture content, energy density and volumetric density (at point of collection)
• Likely locations/regions of availability
• At what point on-farm or in industrial supply chains the waste or residue is generated – or if
the material is a product grown specifically for biofuels, how it is grown and what land is
typically used (this is covered in Section 4.5)
• Any particular transport issues
This information has been summarised in Table 3 below, with feedstock specific details provided in
the factsheets in Appendix C. Please note that the data presented are often sourced from in-depth
analysis conducted in other studies (e.g. on resource potentials), and hence are only indicative. Wide
ranges exist in many cases, depending on the region and different national practices, the season of
harvest and weather impacts year-to-year, and supply chain and any pre-processing steps followed.
In particular, MSW and Commercial & Industrial wastes are not homogeneous feedstocks, and have
very wide ranges, since these resources are comprised of multiple different waste streams.
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Table 3: Summary of descriptive information
Feedstock State Moisture content % LHV (GJ/t) Density
(g/cm3)
Transport issues Classification and land
use Key regions for production
Bio-fraction of MSW Solid general 60%
food 70% 6.3 0.50 Toxicity Waste Population centres
Bio-fraction of C&I waste Solid food 60%
paper, wood 10-20% 7.0 0.50 Toxicity Waste Population centres
Straw Solid 15% 15.0 0.14 Low density Agricultural residue Arable cropping
Corn Stover Solid 13% 14.0 0.20 Low density Agricultural residue Corn regions (US, China, Brazil)
Animal manure Liquid wet manure 90%
poultry litter 35% 1.3* 0.99
Odour, high water,
bio-toxicity Agricultural residue Intensive livestock farming (NW EU)
Sewage Sludge Liquid 96% 0.5* 1.00 Odour, high water,
bio-toxicity Waste Developed population centres
Palm oil mill effluent Liquid 96% 0.8* 1.00 High acidity, water Process residue Malaysia, Indonesia
Empty palm fruit bunches Solid 64% 4.5 0.18 Low density Process residue Malaysia, Indonesia
Tall oil pitch Liquid 0% 38.0 0.95 Toxicity Process residue Pulp/paper mills (US, N EU, E Asia, Brazil)
Crude glycerine Liquid 10% 14.2 1.20 Process residue FAME biodiesel plants (EU, US)
Bagasse Solid 48% 7.8 0.20 Low density Agricultural residue Sugarcane (Brazil, India)
Grape marcs & wine lees Solid 65% 6.2 0.90 High water Process residue Wine regions (Med.)
Nut shells Solid 10% 16.4 0.58 Agricultural residue Nut regions (US, Med., SE Asia)
Husks Solid 10% 13.0 0.035 Low density Process residue Rice regions (China, SE Asia)
Cobs Solid 20% 12.4 0.27 Agricultural residue Corn regions (US, China, Brazil)
Bark, branches, leaves Solid 30% after natural drying 12.4 0.15 Low density Forest residue Existing forest (N EU, N America, Russia)
Saw dust & cutter shavings Solid 20% after drying 15.2 0.35 Process residue Forest industry (N EU, N America, Russia)
Black and brown liquor Liquid 25% 12.0 1.40 Corrosion, toxic Process residue Pulp/paper mills (N EU, N Am, Brz, E Asia)
UCO Liquid 0% 36.0 0.91 Process residue Population centres
Animal fats Cat I & II Solid 0.3% 32.7 0.83 Toxicity Process residue Livestock rendering plants
Miscanthus Solid 16% 13.4 0.14 Low density Product: land using Agricultural land in temperate climates,
avoiding frosts (US, Western EU)
Short rotation coppice Solid 30% after natural drying 12.3 0.24 Product: land using Agric land with high moisture availability
SRF/small round-wood Solid 30% after natural drying 12.3 0.24 Product: land using Existing forest (N EU, N Am, Brz, Russia)
Micro-algae Liquid oil 0% 36.0 0.92 Product: minimal area Warm, sunny climates (MENA, US Gulf)
Macro-algae Solid seaweed 85% 2.0* 1.03 High water Product: sea area using Coastal waters (NW EU, E Asia, Chile)
Renewable electricity Electricity 0% NA NA Grid balancing Product: minimal area High renewable deployment (EU, US, China)
Waste carbon gases Gas 0% 6.2 0.0014 Auto-combustion Process residue Steel mills (China, US, central EU)
Energy densities marked with * are theoretical biogas yields, not the Lower Heating Value of combustion (which would be negative, given the high moisture contents). We note that the EC
classify bagasse and nut shells as agricultural residues, when in fact they are residues of a downstream processing step (sugarcane milling & juice extraction, or de-hulling).
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4.3 Supply potentials
This section assesses the current and 2020 supply potentials of each feedstock, along with the
current and 2020 advanced biofuel production potentials using the feedstock. The feedstock supply
data in Table 4 is presented in million tonnes per year – this is at the standard moisture contents
given in Table 3 (and not in oven dried tonnes). This supply data presents the technical potential of
each feedstock – i.e. the amount of bioenergy resource that can be sustainably collected or grown,
but without considering any competing uses.
• For agricultural residues (such as straw and cobs) and forest residues, these potentials are
lower than the total theoretical potentials, because a significant percentage has to be left to
maintain soil quality. These sustainable collection potentials are given before any other
competing uses are considered.
• For wastes – such as household UCO, the bio-fraction of MSW and industrial waste streams,
palm oil mill effluent and sewage sludge – we present the total waste arising and collected,
but before any recycling, energy recovery or disposal.
• For processing residues – such as commercial/industrial UCO, animal fats, empty palm fruit
bunches, crude glycerine, husks, nut shells, bagasse, grape marcs & wine lees, saw dust &
cutter shavings, black & brown liquor and waste carbon gases – all of these resources are
presented as arisings available for collection, but before any further uses or disposal.
• For “new growth” products grown specifically for bioenergy – such as energy crops, short
rotation forestry, small round-wood and algae – these are presented as the total resource
grown and harvested, but before any other competing uses are considered.
• Renewable electricity is presented in Mtoe/yr instead of Mt/yr, and displays the total size of
the renewable electricity market (not just input power for electrolysis), i.e. before other
competing uses for the electricity are considered. To avoid double-counting of biomass
electricity (e.g. from forestry), we are only considering non-bioenergy renewable power.
The main data sources used for the feedstock supply analysis are: E4tech (2011), NNFCC (2011),
Biomass Futures (2012), Ecofys (2013b; 2013c), plus data from IIASA (2012) and a variety of other
public sources for individual feedstocks. In some cases, reliable data for current feedstock supply was
not available, hence we estimated potentials either by summing available data from key producing
countries, scaling up (or down) data from global or EU estimates, or assuming split-outs where only
combined data was available for several feedstocks. These more uncertain data points are flagged in
Table 4, and may require further (perhaps primary) research to increase the reliability of the data.
Table 4 also provides an indication of any likely expansion after 2020, i.e. whether each feedstock
supply potential is expected to increase significantly to 2030 (↑), is close to a maximum/not
expected to expand further (↔), or is likely to decrease to 2030 (↓). Based on the technology
efficiencies from the selected pathways in Section 4.4, the final columns of Table 4 also provide the
feedstock potentials converted into finished biofuel, in Peta Joules per year. Importantly, these
biofuel production potentials do not consider the availability of sufficient novel conversion plant
capacity to use the feedstocks – these constraints are considered in the ongoing Feasibility study.
However, this is a key distinction between those feedstocks that are supply limited (e.g. UCO and
animal fats), and the majority of other feedstocks that are conversion plant limited.
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Table 4: Summary of feedstock supplies (in wet “as received” tonnes) and biofuel production potentials (i.e. without conversion plant capacity constraints) – both
before any competing uses for the feedstock are considered
Feedstock
Current feedstock supply
(wet Mt/yr)
2020 feedstock supply
(wet Mt/yr) Expansion post 2020? Data
quality
Current biofuel production
potential (PJ/yr)
2020 biofuel production
potential (PJ/yr)
UK EU Global UK EU Global UK EU Global UK EU Global UK EU Global
Bio-fraction of MSW 22 189 861 22 147 1,039 ↓ ↓ ↑↑ Medium 68 591 2,694 68 460 3,253
Bio-fraction of C&I waste 25 133 560 25 104 690 ↔ ↔ ↑↑ Medium 85 460 1,941 87 359 2,390
Straw 7.4 - 11 72 885 7.4 - 11 155 934 ↔ ↓ ↑↑ High 52 405 4,963 52 870 5,240
Animal manure 68 1,521 16,202 68 1,340 18,866 ↔ ↑ ↑↑ Medium 43 969 10,320 43 853 12,016
Sewage sludge 35 632 1,069 37 648 1,183 ↑↑ ↑ ↑↑↑ High 9 161 272 9.5 165 301
Palm oil mill effluent 0 0 159 0 0 338 - - ↑↑↑ High 0 0 60 0 0 127
Empty palm fruit bunches 0 0 51 0 0 109 - - ↑↑↑ High 0 0 81 0 0 172
Tall oil pitch 0.001 0.16 0.4 0.001 0.19 0.5 - ↑↑ ↑↑ High 0.02 5.3 14 0.02 6.6 17
Crude glycerine 0.03 1.0 2.9 0.04 1.4 4.9 ↔ ↔ ↑↑ High 0.25 8.3 25 0.36 12 42
Bagasse 0 0 413 0 0 599 - - ↑↑↑ High 0 0 1,205 0 0 1,748
Grape marcs 0.02 4.1 7.7 0.02 4.1 8.5 ↔ ↔ ↑ High 0.05 9.5 18 0.05 9.5 20
Wine lees 0.004 0.8 1.5 0.004 0.8 1.6 ↔ ↔ ↑ High 0.01 2.6 4.9 0.01 2.6 5.4
Nut shells 0 0.8 10 0 0.8 11 - ↔ ↑↑ Medium 0 4.5 55 0 4.5 61
Husks 0 0.5 120 0 0.5 133 - ↔ ↑↑ Medium 0 2.3 583 0 2.3 645
Cobs 0.01 3.6 36 0.01 3.6 40 ↔ ↔ ↑↑ High 0.04 17 167 0.04 17 185
Bark, branches, leaves 3.4 127 317 3.4 122 316 ↔ ↔ ↑ Medium 15 554 1,377 15 532 1,376
Saw dust & cutter shavings 1.6 37 104 1.6 42 115 ↔ ↑↑ ↑↑ High 8.5 199 552 8.5 221 614
Black and brown liquor 0.28 66 200 0.28 72 246 - ↑ ↑ High 1.9 459 1,392 1.9 498 1,714
UCO 0.13 1.1 2.8 0.19 3.0 7.8 ↔ ↔ ↑↑ High 4.3 37 94 6.6 102 266
Animal fats Cat I & II 0.12 1.2 3.5 0.12 1.3 3.8 ↔ ↔ ↑↑ High 3.7 38 107 3.7 39 119
Miscanthus 0.12 0.9 1.2 0.36 4.1 4.7 ↑↑↑ ↑↑↑ ↑↑↑ Medium 0.6 4.6 6.2 1.8 21 24
Short rotation coppice 0.04 0.3 9 0.11 1.3 11 ↑↑↑ ↑↑↑ ↑↑↑ Medium 0.15 1.2 39 0.46 5.6 47
Short rotation forestry 0 0 0 0 0 0 ↑↑↑ ↑↑↑ ↑↑↑ High 0 0 0 0 0 0
Small round-wood 3.3 333 829 3.3 310 772 ↔ ↑ ↑ High 14 1,417 3,523 14 1,320 3,282
Micro-algae 0 0 0 0 0.0001 0.015 - ↑↑ ↑↑↑ High 0 0 0 0 0.002 0.51
Macro-algae 0 0 0.01 0.01 0.24 2.2 ↑↑↑ ↑↑↑ ↑↑↑ High 0 0 0 0.01 0.24 2.2
Renewable electricity (Mtoe) 2.2 51 403 7.8 82 575 ↑↑↑ ↑↑↑ ↑↑↑ High 67 1,536 12,142 235 2,455 17,316
Waste carbon gases 0.9 10 101 0.9 10 138 ↔ ↔ ↑↑ Medium 3.3 36 375 3.3 37 511
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4.4 Technologies
This technology feasibility section is presented separately from the feedstock feasibility section, since
many of the feedstocks share similarities in the types of conversion technology they can be used in –
it is therefore more useful to give information on the whole list together, rather than for each
feedstock individually.
4.4.1 Suitability
There are many conversion technologies capable of transforming the Annex IX feedstocks into
biofuel – most of which have several conversion steps via intermediate products. The main
technologies under development with relevance for the 2020 timeframe include thermochemical
routes such as gasification and pyrolysis, and biological routes such as anaerobic digestion and
enzymatic hydrolysis. Other technologies further from commercialisation (e.g. hydrothermal
liquefaction, supercritical water gasification) are not in scope, hence not shown here. From the
intermediate products of syngas, bio-oil, biogas, sugars and lipids that we are considering, a wide
variety of different molecules can be created, using technologies such as catalysis, refining,
fermentation and purification.
The full list of feedstocks, conversion technologies, intermediates, upgrading technologies and final
products is shown below in Figure 4. This pathways map shows which feedstocks can be used in
which technologies, and the main steps required to reach a finished biofuel.
For clarity and brevity, similar sub-technologies and processes have been grouped together (e.g.
different gasification reactors such as entrained flow, bubbling, circulating fluidised bed, or fixed bed
have all been included within “Gasification”). We are also not highlighting any individual technology
developer or organisation – a summary of the status of industrial activity in each of the technology
pathways, highlighting the key actors and developers, will be conducted in the Advanced Biofuel
Demonstration Competition Feasibility study.
Co-products and other process inputs are also not shown in Figure 4. The most important co-
products in terms of revenues (and GHG emissions benefits) include glycerine for FAME biodiesel,
digestate for anaerobic digestion, acetone if producing butanol and ethanol together, char from
pyrolysis, naphtha for HVO and FT catalysis, heavy or light ends from refining, heat & power (from
lignin, off-gas combustion or exothermal chemical reactions), and oxygen from electrolysis.
Each feedstock has also been assigned a principal conversion pathway (to represent its most likely
route to producing an advanced biofuel by 2020), in order that the GHG assessment below in Section
4.7, and the economic assessment below in Section 4.5, can be conducted based on this selection.
The feedstock is coloured to match this principal conversion pathway – e.g. UCO, animal fats and
micro-algae are all grey, to reflect their conversion into FAME biodiesel. These principal routes are
however not the only option open to each feedstock – as shown in Figure 4, each feedstock could be
processed in a number of conversion technologies. During the GHG and economic sections below, we
will discuss how the results for the selected pathways could vary had different pathway choices been
made instead.
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34
Figure 4: Potential conversion pathways from each Annex IX feedstock to biofuel. Most likely options (selected for analysis) shown by bold highlights
Advanced Biofuel Feedstocks - An Assessment of Sustainability
35
Technology flexibility varies – some conversion processes are able to use a variety of different
feedstocks, whereas others have much more strictly controlled requirements. We note that because
the feedstocks are often not homogeneous, some fractions of a particular feedstock may not be
suitable for use in a certain technology – e.g. MSW includes waste wood fractions which are not
suitable for anaerobic digestion. Figure 4 is therefore a high level picture of the suitability of each
feedstock based on its major components (e.g. food, green and paper wastes dominate within MSW).
• Oils and fats are most suitable for conventional biodiesel routes (trans-esterification to
FAME and hydro-treatment to HVO). FAME and HVO both require a purification step to
ensure the conversion is not affected by any catalyst poisons – purity requirements are
stricter for HVO. FAME cannot take any feedstocks other than lipids (oils and fats dissolve in
the methanol), and whilst lipids are also the preferred feedstock for HVO, the higher
processing temperatures and addition of hydrogen does also allow heavier oleochemical
refinery products (such as tall oil pitch) to be used.
• Anaerobic digestion is suitable for a wide range of feedstocks, including food waste,
agricultural waste, manures, sewage sludge, abattoir waste and specifically grown crops. AD
plants are increasingly commonly being designed to use a mixture of feedstocks, although for
optimal fermentation conditions, the composition of the feedstock should be fairly
consistent, as should the rate of feeding (NNFCC, 2011). AD systems are engineered to create
the right climatic conditions for anaerobic bacteria, and to efficiently isolate the useful
product streams (methane and digestate). There are many AD system configurations: wet
slurry systems (common in the UK) take high water content feedstock, whereas dry digestors
(common across Europe) are more suitable for silage crops, straws and energy grasses. The
main feedstock requirement is that there is a high % of volatile solids, and low amounts of
indigestible components such as lignin. Fatty feedstocks typically produce higher methane
yields than carbohydrate or protein rich materials. AD technology costs are highly dependent
on scale (with upgrading and grid injection equipment contributing significantly at small
scales), and the amount of additional infrastructure required (e.g. wastes processing).
• The fermentation of lignocellulosic feedstocks is significantly more complicated than “1G”
sugar fermentation, due to the complexity of the feedstock and the challenge in deriving
fermentable sugars. Lignocellulosic material contains both hexose (C6) and pentose (C5)
sugars in the complex polymer forms cellulose and hemicellulose, which are bound by lignin.
Feedstock pre-treatment is required to unlock these C6 and C5 complex polymers from the
lignin, followed by hydrolysis of the polymers to sugar monomers, and then fermentation of
sugars to the biofuel product. Ideal feedstocks therefore have low amounts of highly soluble
lignin, high reactivity of the cellulose and hemicellulose, low crystallinity of the cellulose and
high porosity of the material. C6 sugars are also more cheaply and efficiently fermented than
C5 sugars, hence the starting composition of the feedstock is important. It is also important
that the by-products from pre-treatment and hydrolysis are minimised, as these can inhibit
fermentation – feedstocks should minimise ash and acetyl contents. As shown in Figure 4, all
the woody biomass and agricultural residue feedstocks would be suitable for lignocellulosic
ethanol or butanol production (enough flexibility in pre-treatment options), although yields
will vary significantly.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
36
• Pyrolysis conversion technologies cover a range of different temperatures and reactor
designs; however, fast catalytic pyrolysis is the usual choice for maximising liquid yields in the
shorter residence time, and minimising solid and gaseous by-products. Feedstocks most
suitable for fast pyrolysis are those low in moisture and ash, with a high volatile matter
content. Being able to be easily chipped or reduced to a small particle size is also important
to improve reaction dynamics. As shown in Figure 4, all the woody biomass and agricultural
residue feedstocks would be suitable for pyrolysis, as are the drier fractions of manure, MSW
and industrial wastes (although output oil quality could vary significantly).
• Gasification also covers a range of different temperatures and reactor designs; however,
making a syngas suitable for further upgrading into liquid or gaseous biofuel will usually limit
the choices to those gasifiers operating without nitrogen dilution (i.e. oxygen or steam-
blown), and at high temperatures (purer syngas with less tars). Feedstock requirements vary
considerably between gasifier designs, with plasma gasifiers being the most tolerant to
heterogeneous feedstocks (typically taking mixed wastes), down to entrained flow gasifiers
needing very stringent criteria to be met (small, uniform particles). Wetter feedstocks will
typically produce more hydrogen and methane in the syngas (and less CO and CO2) – the
methane is an advantage for bioSNG synthesis, but a disadvantage for longer-chain FT
catalysis. However, wetter feedstocks also reduce efficiency and gasification temperatures
making tars more likely. Ash content and its melting characteristics are important, since
molten ash can cause serious agglomeration of fluidised bed designs. Pressurised operation
is an advantage for downstream catalysis processes, but requires careful preparation and
sizing of the feedstock to avoid input clogging issues – some agricultural residues are
problematic in this aspect, with developers historically preferring cleaner woody materials
instead of straw or bagasse. In general, similar to pyrolysis, ideal feedstocks for gasification
have low moisture and ash, and a high volatile matter content. As shown in Figure 4, all the
woody biomass and agricultural residue feedstocks would be suitable for gasification
(depending on the gasifier design chosen), as are the drier fractions of manure, MSW and
industrial wastes (although output syngas could vary significantly).
4.4.2 Commercialisation status
Different technologies within the pathways shown in Figure 4 are at different levels of maturity. A
commonly used scale to illustrate relate levels of maturity is the TRL (Technology Readiness Level),
with TRL 1-4 being lab based, TRL 5 pilot stage, TRL 6-7 demonstration stages at larger scale, and TRL
8 a first commercial plant, leading to mass deployment at TRL 9.
The current TRL status of the main conversion technologies is given below in Figure 5. This highlights
that only a few routes are fully commercial and widely deployed – namely, “1G” ethanol (C6 sugar
fermentation) and “1G” biodiesel (FAME esterification). HVO and AD + biogas upgrading have been
more recently commercialised – however, there is then a noticable gap with the majority of
technologies currently at the TRL 4-6 stage, reflecting the difficulties faced by innovative
technologies in overcoming the commercialisation “valley of death”.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
37
Figure 5: Current TRL status of the main conversion technologies
Progress in scaling up and demonstrating new conversion technologies has been mixed in recent
years. Technologies that have made significant progress to TRL 6-7 include: LC ethanol (several
different pre-treatment technologies being used in the US and EU) and Syngas fermentation (from
biowaste and steel mill gases), with demonstration plants built recently. Gasification + Methanol has
already reached TRL 8, but only using crude glycerine to date (which is much easier to process into
syngas than solid biomass). Gasification + bioSNG and Pyrolysis oil + upgrading are also making good
progress from the pilot stage with demonstration plants in construction and start-up, whereas
Gasification + DME and Aqueous phase reforming routes are still waiting on a significant scale
demonstration step to be taken – but developers remain active.
Notably, 1G butanol has seen relatively slow progress, with developers and oil majors now projecting
much lower capacity coming on-stream or being retrofitted by 2020, compared to the peak of the
hype surrounding butanol in 2010. We do however note that there are active Acetone-Butanol-
Ethanol (ABE) plants operating in China. LC butanol routes are unlikely to be followed until LC
ethanol and 1G butanol have been sufficiently developed.
In recent years, BTL (Gasification + FT catalysis) has suffered with leading developers becoming
insolvent or abandoning planned projects – although a few technology providers do still remain.
Similar set-backs have occurred for Gasification + Mixed alcohols. Whilst the technology
components for these routes are relatively well known, de-risking and accessing finance for such high
capital cost projects remains a major challenge.
Research CommercialPilot Demonstration
Gas if + Methanol
1G ethanolLC ethanol
AD + Biogas upgradingGasif + H2
TRL
Gas if + Mi xed alcohols
Pyrolys is oil + upgrading
Gas if + FT
Gas if + DME
Syngas fermentation
Gas if + bioSNG
Renewable electrolysis
1G butanol
Aqueous phase reforming
Aerobic fermentation
CO2 + H2 catalysis
1-3
LC butanol
4 5 6 7 8 9
FAME
HVO
(us ing glycerol)
Advanced Biofuel Feedstocks - An Assessment of Sustainability
38
Interestingly, Gasification + H2 was investigated by researchers as early as 2000, but has been on
hold since due to unattractive economics versus natural gas reforming. Micro-algae and aerobic
fermentation of sugars is at the pilot scale, but some developers are now focusing first on the
extraction of high-value chemicals instead of biofuels. A macro-algae sea trial was also recently
damaged beyond repair, but other sites and interest remain globally.
Based on industry experience, and project construction timelines, new biofuel technologies can take
3-5 years to progress by one TRL. Although several developers used to have ambitious plans for
scaling up, and avoiding intermediate demonstration steps (e.g. going straight from TRL 5 to 8), many
of these companies have been unsuccessful, or not progressed – the current industry is noticeably
much more cautious in their announcements. There is still potential for developments in one chain to
promote another chain (“piggy-backing”) – e.g. wood gasification scale-up, micro-channel catalysis,
or retrofitting of 1G ethanol plants to use lignocellulosic feedstocks and/or produce butanol. We
note some technologies are likely to require development using lower cost 1G sugar feedstocks,
before making the switch to lignocellulosic sugars, but this discussion is outside of the project scope.
There are therefore only a handful of advanced biofuel pathways that could contribute meaningful
volumes of biofuels by 2020 (i.e. reach TRL 8), in addition to those already at this stage (1G ethanol,
FAME, HVO, AD + upgrading). These include technologies currently at TRL 6 or higher, such as LC
ethanol, 1G butanol (and potentially LC butanol), pyrolysis oil upgrading and gasification routes to
syngas fermentation, FT, methanol, mixed alcohols and bioSNG. All these routes have a chance
(depending on the investment environment, public support and relative economics) of overcoming
the “valley of death” and finally scaling up. Renewable electrolysis could also make a contribution
depending on the roll out of hydrogen infrastructure.
4.5 Economics
This economics section presents current market value data for each Annex IX feedstock, along with
the estimated biofuel production costs for each of the selected supply chains.
Price data for each individual feedstock (in £/t and £/GJ) is presented in Table 5. Some feedstocks are
very rarely traded (e.g. black liquor, bagasse, husks, grape marcs & wine lees), hence the data is
particularly thin. Other feedstocks are either assumed by various references to have a zero price (e.g.
animal manure, sewage sludge, POME), or command a negative price to reflect gate fees for
anaerobic digestion (e.g. MSW, industrial wastes). Micro-algae and macro-algae prices have been
estimated from their current production costs.
We note that these prices are indicative ranges only, as they are subject to market fluctuations over
time, often show significant geographic variation, and also depend on volumes, contract terms and
the feedstock quality (which again can vary massively). We have presented ranges where the data is
available, but giving priority to most recent data sources (e.g. we are not presenting UCO price data
from 2011 and 2012, as this has been superseded by 2013 prices).
Based on these feedstock prices, and the point in the supply chain at which they apply, we have then
been able to derive the costs associated with each full supply chain, from feedstock through
conversion to delivered fuel at a refilling station. The main data sources used in this analysis were:
Advanced Biofuel Feedstocks - An Assessment of Sustainability
39
• Feedstock and biofuel transport costs, natural drying and chipping costs: Based on supply
chain costs collected during E4tech (2010), updated during our work for the ETI’s Biomass
Value Chain Modelling project, and validated with 2013 industry confidential data
• Biofuel conversion plant costs and efficiencies: Based on data from SKM (2011), Humbird et
al. (2011), European Commission (2011), Neste Oil (2006; 2007; 2008), Swanson et al. (2010),
Hamelinck & Faaij (2006), IRENA (2013), Bowen et al. (2010), RENEW (2008), AMEC (2009),
Roads2HY (2009) and Holmgren (2013). Updated in ETI Biomass Value Chain Modelling
project, and validated with 2013 industry confidential data
Import tariffs come from WTO (2013), with Distribution and refuelling costs from APEC (2011), Caula
(2011) and Roads2HY (2009).Table 6 presents the outcomes of this analysis. The regions selected are
examples of where the feedstock is likely to be produced in large quantities, and then the rest of
the supply chain is based on the most likely biofuel conversion pathway and downstream distribution
to enable the consumption of the biofuel somewhere within Europe.
In some cases the feedstock is only produced in one region, hence the choice of example region is
straight-forward. In other cases, there are a large number of different production regions and
possible supply chains – but for the sake of conducting a meaningful and understandable analysis of
the biofuel economics and GHGs, we mainly only focused on one example route/region. Exceptions
where we have considered more than one chain are corn stover (the US version of EU straw), and
small round-wood (in both the US and in the EU), we judged that these regions could be equally likely
to produce a fuel that ends up in the UK. For the wastes, we mainly chose the UK as the region of
interest, because AD biomethane is unlikely to be shipped into the UK from elsewhere globally (a
similar reason to why POME is excluded from the economic and GHG analysis).
Key points to note are that the costs of each step are given in terms of £/GJ biofuel – hence the
upstream feedstock cultivation and handling steps have been divided by the biofuel conversion
efficiencies (GJ main output/GJ feedstock). Transport costs depend strongly on the distance and
feedstock volumetric density, hence the particularly high transport costs for empty palm fruit
bunches, husks and bark, branches & leaves. Distribution and filling station costs are fairly uniform
across all the chains (except for less mature hydrogen infrastructure), with shipping biofuel to the EU
and paying import tariffs also adding to costs.
The highest biofuel production costs are seen for macro-algae and micro-algae, reflecting the fact
that algae cultivation is yet to be commercialised. Renewable electrolysis is currently an expensive
way of producing transport fuel, due to the cost of the electricity. Bio-methanol is also expensive,
since crude glycerine costs have risen sharply in recent years, and biomethane costs from animal
manure are high due to small scales and costly upgrading & injection equipment.
The cheapest biofuel production costs are seen for biomethane from wastes (MSW and industrial),
due to the negative price of the feedstocks (gate fees) helping off-setting some of the high
conversion plant costs. However, the product being displaced (natural gas) is significantly lower cost
than liquid fossil fuels. Despite high feedstock prices, UCO, animal fats and tall oil pitch also produce
low cost biofuels due to high conversion efficiencies and low conversion costs. Many of the
agricultural residues and woody resources fall in the mid-range of biofuel production costs, due to
low feedstock costs, but high conversion costs.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
40
Table 5: Summary of feedstock prices
Feedstock Current price (£/t) Current price (£/GJ) Point in supply chain Data quality Reference
Bio-fraction of MSW -41 (-46 to -24) -6.5* Gate fee High WRAP (2013) Gate Fees Report
Bio-fraction of C&I waste -41 (-46 to -10) -5.9* Gate fee High WRAP (2013) Gate Fees Report
Straw 63 (48 to 75) 4.2 Farm gate High Farming Online (2013)
Corn stover 39 2.8 Farm gate Theoretical Purdue University (2011)
Animal manure 0 (0 to 34) 0.0* Farm gate High Biomass Futures (2012) Atlas of EU biomass potentials
Sewage Sludge 0 (-41 to 0) 0.0* Water treatment works High Ofwat (2010), Wrap (2013)
Palm oil mill effluent 0 0.0* Mill Medium IFC (2009)
Empty palm fruit bunches 3 (2 to 4) 0.7 Mill Medium Eco-ideal consulting Malaysia (2013) pers. comm.
Tall oil pitch 420 11.1 Tall oil refinery High Industry confidential (2013) pers. comm.
Crude glycerine 253 17.9 FOB traded High Oleline (2013) Glycerine Market Report
Bagasse 8.5 (2.8 to 34) 1.1 Sugar mill High Industry confidential (2013) pers. comm., Pecege (2011)
Grape marcs 54 9.4 Dried and delivered Medium MixBioPells.eu (2012)
Wine lees 54 9.4 Dried and delivered Poor Assumed same as grape marcs, no other data available
Nut shells 67 (49 to 85) 4.1 Factory gate High de Pinares (2013)
Husks 97 (80 to 110) 7.5 CIF traded High Industry confidential (2013) pers. comm.
Cobs 57 (46 to 68) 4.6 Farm gate Theoretical Purdue University (2011)
Bark, branches, leaves 39 (34 to 44) 3.1 Delivered to buyer Medium Industry confidential (2010)
Saw dust & cutter shavings 67 4.4 Mill High European Pellet Council (2012)
Black & brown liquor 112 (0 to 175) 9.3 Pulp & paper plant Medium Based on energy value, Biomass Futures (2012)
UCO 724 20.1 FOB traded High Platts (2013)
Animal fats Cat I & II 480 12.6 FOB traded High Ecofys (2012)
Miscanthus 53 4.0 Farm gate High Terravesta (2013)
Short rotation coppice 50 4.0 Farm gate High E4tech and NNFCC (2013)
SRF/small round-wood (UK) 42 3.5 Roadside High Tubby (2012)
SRF/small round-wood (US) 32 2.6 Roadside High WRI (2011) North American Wood Fiber Review
Micro-algae 1,710 47.5 Plant gate Medium E4tech (2011) As used in CT TINA analysis
Macro-algae 48 23.8* Landed on shore Medium E4tech (2011) As used in CT TINA analysis
Renewable electricity £95/MWh 26.4 Renewable project High DECC (2013) Onshore wind strike price
Waste carbon gases 42 6.7 Steel mill Medium Holmgren (2013), DECC (2013)
Those prices marked with * are based on the biogas energy potential, not the combustion LHV – i.e. the calorific values given in Table 3
Advanced Biofuel Feedstocks - An Assessment of Sustainability
41
Table 6: Summary of biofuel production costs (£/GJ biofuel)
Feedstock Region Resource Drying,
chipping
Transport
to plant
Biofuel
conversion
Conversion
efficiency Technology
Transport
to EU
Import
tariffs
Transport,
filling station
Total delivered
biofuel
Bio-fraction of MSW UK -13.1 - 27.8 49% AD + upgrade - - 3.0 18
Bio-fraction of C&I waste UK -11.8 - 27.8 49% AD + upgrade - - 3.0 19
Straw UK 11.1 2.1 9.8 37% LC ethanol - - 3.5 26
Corn stover US 7.4 1.2 9.8 37% LC ethanol 4.5 4.0 4.8 31
Animal manure UK 0.0 2.2 33.3 49% AD + upgrade - - 3.0 39
Sewage Sludge UK 0.0 - 23.7 49% AD + upgrade - - 3.0 27
Palm oil mill effluent SE Asia 0.0 - AD biogas Not imported, hence not analysed further
Empty palm fruit bunches SE Asia 2.0 4.2 14.6 35% FT diesel 1.5 1.4 3.6 27
Tall oil pitch EU 12.4 0.8 3.6 89% HVO - - 2.9 20
Crude glycerine EU 29.8 - 4.9 60% Methanol - - 3.7 38
Bagasse Brazil 2.9 0.2 - 9.8 37% LC ethanol 3.2 4.0 4.8 24
Grape marcs EU 23.3 1.7 9.8 37% LC ethanol - - 3.5 38
Wine lees EU 15.9 1.5 9.1 54% 1G ethanol - - 3.5 30
Nut shells EU 11.7 0.7 14.6 35% FT diesel - - 2.9 30
Husks EU 10.4 9.6 9.8 37% LC ethanol - - 3.5 33
Cobs US 12.3 1.0 9.8 37% LC ethanol 4.5 4.0 4.8 36
Bark, branches, leaves EU 3.2 1.8 3.9 14.6 35% FT diesel - - 2.9 26
Saw dust & cutter shavings EU 12.7 1.1 14.6 35% FT diesel - - 2.9 31
Black and brown liquor EU 16.1 - 12.9 58% DME - - 3.0 32
UCO UK 21.3 0.1 0.5 94% FAME - - 3.5 25
Animal fats Cat I & II UK 15.6 0.2 0.5 94% FAME - - 3.5 20
Miscanthus UK 10.6 2.8 9.8 37% LC ethanol - - 3.5 27
Short rotation coppice UK 11.5 1.8 1.9 14.6 35% FT diesel - - 2.9 33
SRF/small round-wood UK 9.9 1.9 1.9 14.6 35% FT diesel - - 2.9 31
SRF/small round-wood US 7.0 1.7 1.4 9.8 37% LC ethanol 2.8 4.0 4.8 31
Micro-algae US 50.4 1.0 0.5 94% FAME 1.2 3.3 4.2 60
Macro-algae UK 48.2 1.2 11.5 49% AD + upgrade - - 3.0 64
Renewable electricity UK 36.7 - 7.8 72% Electrolysis - - 10.3 55
Waste carbon gases EU 11.1 - 7.9 60% Eth ferment - - 3.5 23
Advanced Biofuel Feedstocks - An Assessment of Sustainability
42
4.6 Sustainability
The sustainability of each feedstock has been assessed by conducting the following “risk screening”
exercise, in order to highlight if there are certain factors that could be problematic for a particular
feedstock:
1. Identifying the competing uses of the feedstock
2. Determine the most likely substitute resources for these competing uses if the feedstock was
to be diverted to biofuels conversion, or the land types used if new feedstock is grown
3. Indicate the risk of significant indirect GHG emissions associated with these substitutes
4. Assess other associated direct and indirect environmental and social impacts. Note that we
have not assessed any potential benefits, only the potential risks.
5. Indicate the risk of the diversion having a significant impact on feedstock prices
6. Estimate the direct GHG emissions associated with using the feedstock for biofuel production
Competing uses
Table 7 sets out the existing uses identified for each feedstock, based on the overall feedstock
availability and tonnages currently entering each market. This data is again presented for the region
in which the feedstock is most likely to be produced, when considering biofuel routes ending in
Europe. These are the same regions that we are using for the GHG and economics calculations. The
cells highlighted in purple indicate those existing uses which are most likely to be in competition with
biofuels production. This high-level analysis considers tonnages for the whole feedstock base, and
does not examine the quality of each stream and which would be most suitable for specific biofuel
conversion technologies. The resulting messages are that:
• Feedstocks currently disposed of to landfill or burnt without energy recovery could be
available for biofuels.
• Feedstocks left on the ground, spread to land or uncollected could also be resources for
biofuels, provided the feedstock is extracted sustainably (or digestate is returned).
• Heat and power sectors will commonly be in competition where sufficient volumes of the
material are flowing into this sector, since transport biofuels are a similarly low value, high
volume energy use of biomass feedstocks.
• Animal bedding and feed are only significant considerations for a few feedstocks, namely,
straw, crude glycerine, and some sawmill residues.
• Industrial uses vary, with many of the chemicals sectors being high-value, niche markets that
are either unlikely to be affected (due to small volumes), or their high willingness to pay.
However, other industries are at a much larger scale and more price sensitive, such as paper
& panel board using small round-wood and some types of sawmill co-products.
• For those feedstocks specifically grown for biofuels (cells highlighted in green), the current
competing uses identified are relatively unimportant, however, the land that will be grown
on is important to consider.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
43
Table 7: Identification of current competing uses (highlighted cells show key competing uses)
Region Disposal Left, or spread to
land
Heat and/or
power Compost
Animal feed &
bedding Industrial Uses Other
Bio-fraction of
MSW UK
9.6 Mt/yr
(not all bio)
4.9 Mt/yr
(not all bio), 0.3
Mt/yr food to AD
5.5 Mt/yr green
waste, 0.3 Mt/yr
food compost
2.5 Mt/yr MBT
(not all bio)
Bio-fraction of
C&I waste UK
11.3 Mt/yr (not all
bio)
2.2 Mt/yr land
recovery (not all bio)
2.7 Mt/yr
(not all bio), 0.07
Mt/yr food to AD
0.07 Mt/yr of
green waste
8.5 Mt/yr recycled in
paper industry
2.3 Mt/yr MBT
(not all bio)
Straw UK
Incorporation 11.7
Mt/yr, 0.6 - 4.2 which
can be extracted sust.
0.52 Mt/yr 5.8 Mt/yr fodder and
animal bedding
0.47 Mt/yr for
mushrooms & frost
protection
Animal manure UK
64 Mt/yr spread to
land, could go via AD
0.7 Mt/yr chicken
litter for power,
0.3 Mt/yr to AD
<0.01 Mt/yr
Sewage sludge UK
5.7 Mt/yr spread to
land without
treatment
6.4 MT/yr
incineration, 23.4
Mt/yr to AD biogas
Palm oil mill
effluent SE Asia
Most discharged
via open ponds
Increasingly
treated by AD
Empty palm
fruit bunches SE Asia
40.8 Mt/yr burnt
without energy
recovery in past
Low but increasing
use in onsite heat
and power
5.1 Mt/yr mulch
or composted
5.1 Mt/yr to paper and
board production
Tall oil pitch EU 0.41 Mt/yr on-site
heat and power
Crude glycerine EU
~0.1 Mt/yr heat
and power use (via
biogas)
0.3 Mt/yr low value
sales into animal feed
& waste water treat
0.56 Mt/yr upgraded for
chemical, food, and
pharmaceutical markets
Up to 0.2Mt/yr
used to make
bio-methanol
Bagasse Brazil
165 Mt/yr burnt
without energy
recovery in past
207 Mt/yr on-site
heat and power,
some off-site
Animal feed uses
under investigation
41.3 Mt/yr paper and
board industry
Grape marcs &
wine lees EU
Mulch,
composting
Used for alcohol, food,
food additives & others
Nut shells EU 0.4 Mt/yr heat and
power
0.4 Mt/yr various
industrial uses
Husks
EU
Globally: 60 Mt/yr
of rice husks for
on-site steam
Unknown quantity of
maize husks to whole
crop silage for animal
feed and AD
Globally: 60 Mt/yr of
rice husks to silica-based
industries, materials,
fertilisers
Advanced Biofuel Feedstocks - An Assessment of Sustainability
44
Region Disposal Left, or spread to
land
Heat and/or
power Compost
Animal feed &
bedding Industrial Uses Other
Cobs US
120 Mt/yr left on
land or incorporated.
36 Mt/yr could be
extracted sustainably
Minor use in heat
and power
Unknown quantity to
whole crop silage for
animal feed & AD
Various industrial uses
Bark, branches,
leaves EU
Up to 56 Mt/yr may
be available in the EU
Heat and power
sector minor use
Mulch,
landscaping
Animal bedding,
minor market
Panel board
Saw dust &
cutter shavings EU
On-site heat and
power, pellet
production
Cutter shavings for
animal bedding
Paper and panel board
Black & brown
liquor EU
85 Mt/yr on-site
heat and power
UCO UK
2.0 Mt/yr disposal
in the EU that
may be collected
0.07 Mt/yr EU chemicals
demand
0.98 Mt/yr to
biodiesel in EU
Animal fats
Cat I and II UK
Cat I & II: 0.85
Mt/yr to heat &
power in EU
Cat III: used for animal
feed, oleochemicals,
soaps, pet food
0.40 Mt/yr to
biodiesel in EU
Miscanthus UK 0.12 Mt/yr to
power and heat
Estimated ~0.04
Mt/yr to bedding
New growth
for biofuels
Short Rotation
Coppice UK
0.036 Mt/yr to
power and heat
New growth
for biofuels
Short Rotation
Forestry UK
New growth
for biofuels
Small round-
wood
UK
US
Up to 2.3 Mt/yr
growing and
harvestable
~1 Mt/yr to paper &
panel board markets,
fencing & furniture
Micro-algae
Macro-algae
US
UK
High value markets inc.
food, feed, cosmetics
pharmaceuticals
New growth
for biofuels
Renewable
electricity UK
100% use in power New capacity
for renewable
transport fuels
Waste carbon
gases EU
~50% steel mills
flare without
energy recovery
~50% steel mills
combust CO for
heat and/or power
Pure CO2 streams may
be used in food & drink
manufacture
Advanced Biofuel Feedstocks - An Assessment of Sustainability
45
Substitute resources and risk of indirect GHG emissions
For each of the key competing uses, we next explored the alternative resource options identified if
the Annex IX feedstock was to be diverted to biofuels conversion. These substitutes are displayed in
Table 8. We have also highlighted in red (and in the text below) those substitute resources that are
likely to present the highest risk in terms of indirect GHG emissions (either due to being a fossil fuel,
or being land-using crops that could cause indirect land use change, ILUC). Feedstock specific details
are provided in the factsheets in Appendix C.
• Disposal to landfill or burning without energy recovery does not require replacement
resources if the material is diverted to biofuels production.
• Feedstocks left on the ground or uncollected also do not require replacement resources if
the material is extracted sustainably for biofuels production – this applies to straw, cobs,
sugarcane trash, forestry residues and small round-wood (all those highlighted in light blue
in Table 8). These resources also play a key role in potentially replacing other feedstocks that
would be diverted to biofuels production from other sectors (notice the mention of chips
and straw as the replacement options given in several rows in Table 8) – hence there is a
need to ensure that these feedstocks are extracted in a truly sustainable manner.
• For manure and sewage sludge, no replacement resources are required, provided that the
AD digestate is returned to the land to replace the manure or sludge fertiliser value.
• Decreased feedstock availability for heat and power sectors could have different impacts,
depending on the boiler flexibility and feedstock form. In the near-term, the indirect GHG
impact could be high, since users burning liquid feedstocks could replace the biofuel
feedstocks with heating fuel oil, those using solid feedstocks could use coal, and those using
biogas could use natural gas instead. All these options would have significant GHG
emissions, and hence significantly reduce the overall system GHG savings of producing
biofuel from that feedstock. However, as the move towards decarbonisation gathers pace in
the UK and EU, these users may no longer be willing (or can afford) to use fossil fuels, and
may instead choose to switch to using solid biomass feedstocks such as straw, wood chip
and pellets (with boiler modifications if required). Provided these additional resources are
sustainably extracted (e.g. from collectable straw, forestry residues or small round-wood),
this indirect GHG substitution impact in the heat & power sector would typically be
significantly lower than if using fossil fuels as the substitute resource. One stakeholder has
noted that this indirect substitution in the heat & power sectors is more of a risk in countries
with cheap (or subsidised) fossil fuels – with the price levels seen in the EU, there is less
incentive to substitute with fossil fuels, and a greater likelihood of substitution with
sustainable alternatives.
• Animal bedding is only a significant consideration for straw and some saw-mill residues –
both can substitute the other, but each will also rely on additional resource coming from
more collected straw or forestry wood chips. We note that straw used for animal bedding
(one of the major competing uses) is commonly return to land in the form of manure, thus
ensuring that nutrient or organic matter depletion does not occur. However, the use of
straw in animal bedding is still a competing use for the “clean” resource – once utilised as
Advanced Biofuel Feedstocks - An Assessment of Sustainability
46
animal bedding, the “dirty” resource is generally classified as dry manure, and hence the
considerations for ensuring sustainability of animal manures now apply.
• Animal feed is only a significant consideration for some straws and crude glycerine. These
feedstocks serve different and particular purposes – barley straw is mainly eaten for its
roughage, and could be replaced by hay or other silage grasses, but this would either require
new areas of arable or pasture land to be dedicated to this production (risking ILUC), or
greater efficiency and productivity from existing grasslands (and higher efficiency in storage
and use/feeding). Crude glycerine is mainly used as a feed binder, although promotes
carbohydrate uptake, hence would be replaced by corn, starch and sugar crops – again,
possibly requiring new arable land areas, or productivity and efficiency increases. Using
straw and crude glycerine for animal feed could therefore lead to indirect GHG emissions,
unless farming output is improved to provide the additional substitute resources without
additional land use (or fertiliser use and soil carbon changes). Industry stakeholders have
highlighted that the animal feed market is one of the most complex demand areas, and that
the exact substitutions that would occur in these markets are hard to quantify in isolation.
We therefore note that further validation and analysis of the animal feed market would be a
valuable addition to the scope of this study.
• Crude glycerine processing to refined glycerine has multiple uses in the chemicals, feed and
food markets. It is likely that any diversion would be replaced with fossil-derived glycerine or
propylene glycol – again, significant indirect GHG emissions impacts. IEEP (2013) also points
out that extra incentives to increase the use of crude glycerine as a biofuel feedstock may
improve the profitability of FAME biodiesel production, and hence have a knock-on impact
via greater virgin vegetable oil consumption (and hence ILUC risks).
• For composting uses, such as some of the green household waste streams within MSW, any
diversion to biofuels needs to avoid substitution with fossil-derived fertiliser or peat –
ideally, digestate from AD could fulfill the same nutrient requirements (although potentially
lacking some of the soil structure benefits). Grape marcs and wine lees are occasionally used
for compost or mulch (hence could face the same substitution risks), but are increasingly
seen as high-value feedstocks for processing into spirits – we note that EU legislation (EC,
2008) states that all grape marcs and wine lees should be treated via ethanol fermentation.
• Paper & panel board industries have few options but to find new supplies of wood if their
feedstocks (small round-wood and sawmill co-products) are diverted to biofuels. These
industries are already recycling a high percentage of the waste wood streams (around 70%
recycling of wood fibres occurs in Europe), and require a certain percentage of virgin
material to maintain product quality. This would therefore require additional forestry
residue or small round-wood resource to be extracted sustainably – although we note that
the available surplus resource of small round-wood and forestry residues is large, and the
forestry industry is able to intensify production (up to certain sustainable yield limits). Some
limited substitution of wood with other agricultural residues (e.g. straws) might be possible
for some materials applications.
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Table 8: Likely replacement resources if feedstock diverted away from existing uses (significant indirect GHG risks highlighted in red)
Region Disposal Left, or spread to land Heat and/or power Compost Animal feed
& bedding Industrial Uses Other
Bio-fraction of MSW UK None needed Natural gas, wood chip Peat, fertiliser,
AD digestate
Bio-fraction of C&I waste UK None needed Natural gas, wood chip More wood chip
Straw UK None if extract sust.
Hay/silage for
feed, sawdust
/chip for bed
Animal manure UK Digestate post-AD
Sewage sludge UK Digestate post-AD Natural gas
Palm oil mill effluent SE Asia None needed
EPFBs SE Asia None needed Natural gas, wood chip
Tall oil pitch EU Fuel oil, wood chip
Crude glycerine EU Fuel oil, wood chip Corn, sugars Fossil crude oil
Bagasse Brazil None needed Cane trash if extract
sust.
Grape marcs & wine lees EU Peat, fertiliser,
AD digestate More grapes?
Nut shells EU Coal, wood, straw
Husks EU Coal, wood, straw
Cobs US None if extract sust. Hay/silage for
feed
Bark, branches, leaves EU None if extract sust.
Saw dust & cutter shavings EU More wood chip/pellet More wood
chip, straw
More wood chip/
waste, straw
Black & brown liquor EU Fuel oil, wood chip
UCO UK None needed
Animal fats Cat I and II UK Fuel oil, wood chip
Miscanthus UK Likely agric. land
Short Rotation Coppice UK Likely agric. land
Short Rotation Forestry UK Land used
Small round-wood UK None if extract sust. More wood chip
Micro-algae US Likely barren, small
Macro-algae UK Coastline, out at sea
Renewable electricity UK Marginal electricity Minimal area or barren
Waste carbon gases EU None needed Natural gas
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48
For the “new growth” feedstocks highlighted in green within Table 8, we have also considered the
likely amount and type of land used:
• Energy crops such as Miscanthus and Short Rotation Coppice will typically be grown on
agricultural land (either arable land as presently is the case, or potentially some pasture or
grass lands in the future). These both present an ILUC risk, through the displacement of
arable crops or livestock elsewhere globally, unless the land they are grown on has no other
uses, would otherwise be taken out of production, or can be sustainably intensified. As
energy crops do not generate co-products, avoiding these indirect impacts is only likely if
strict implementing mitigation measures are implemented – such as protecting high carbon
stock land, above baseline yield increases, supply chain efficiencies and farming system
integration (E4tech, 2011). Assuming an average yield of 14 t/ha/yr across a typical
plantation lifetime, then Miscanthus and Short Rotation Coppice would produce ~170 PJ/yr
for every 1 million hectares of land grown.
• Lower risk feedstocks include algae and new supplies of renewable electricity. Micro-algae
production facilities are likely to have a small footprint, and given the need for warmth,
sunshine and water, these plants could be situated on non-productive, barren land near the
coast in regions such as the Middle East, US Gulf or Australia. Macro-algae will be grown in
large areas offshore, but typically near the coast to minimise costs – the most productive
waters globally are expected to be Eastern Asia, NW Europe and Chile. For renewable
electricity, we are assuming that a new production site is constructed for the purposes of
generating renewable hydrogen. Very little land is taken up by establishing wind-farms
(farming can continue around the towers), and solar PV farms could be established on non-
productive land, or be building-integrated if at a smaller scale.
Environmental and social impacts of diversion
The use of biomass feedstocks for biofuel has impacts beyond the volumes supplied to other energy
and non-energy markets, in particular, the range of negative impacts that it can have on the
ecosystem services provided by the natural environment (e.g. forests, rivers, soil and air). We have
therefore assessed the extent to which the different feedstocks listed are likely to have these
impacts, and whether they might also have indirect impacts (through the substitutes for the
competing uses identified above). We note that some feedstocks may have environmental or social
benefits, but the project scope is to look at potential risks, and hence we have only focused on the
potential negative impacts.
The impact categories we are assessing cover environmental aspects such as species biodiversity,
landscape/visual, forest regeneration, soil and water, as well as social impacts covering food prices
and security, land and labour rights. For each feedstock, we have provided a summary classifying the
level of risk in each impact category as High, Medium or Low. This is summarised in Table 9 – factors
categorised as High risk are shown in Red, with Medium risk in Orange, and Low risk in Green. The
text provided refers only to the indirect impacts, i.e. whether substitute resources in competing use
sectors will cause environmental or social impacts.
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Table 9: Summary of environmental and social factors (Red = High risk, Orange = Medium risk, Green = Low risk. Text represents indirect impacts)
Feedstock Region Environmental Impacts Social impacts
Assumptions Species bio-
diversity
Landscape/
visual
Forest
regen. Soil Water
Food
security
Land
rights
Labour
rights Other
Bio-fraction of
MSW UK Compost Diverted from landfill, compost or incineration
Bio-fraction of C&I
waste UK Diverted from landfill
Straw UK &
US Wood, hay Hay Wood
Wood,
hay
Wood,
hay Hay
Low risk across all factors if only taking additional
sustainable extraction. If displace animal feed/bedding,
assume forest residues and hay/silage available locally
Animal manure UK Transport AD may have env. benefits, but extra transport needed
Sewage sludge UK AD may have env. benefits
POME SE Asia AD may have env. benefits
Empty palm fruit
bunches SE Asia Diverted from incineration without energy recovery
Tall oil pitch EU Wood Wood Wood Wood Transport Diverted from heat & power, assume new forest
residues are available locally
Crude glycerine EU Feed, wood Feed Wood Feed,
wood
Feed,
wood Feed Transport
Medium risks where diverted from animal feed (needing
more sugars/corn to be grown). Heat & power diversion
requires more supply of sustainable fuels
Bagasse Brazil Cane trash Cane
trash
Cane
trash
Low risk across all factors if only diverted from burning.
If displace heat & power, assume other sustainable agric
residues available (e.g. cane trash)
Grape marcs EU Fertiliser Fertiliser Spirits
prod.
Impacts to existing wine industry. May have to go to
ethanol under EU legislation. Some diverted from mulch
and composting, impact reduced if good management
Wine lees EU Spirits
prod.
Impacts to existing wine industry. May have to go to
ethanol under EU legislation
Nut shells EU Transport Diverted from heat & power
Husks EU Transport Diverted from heat & power
Cobs US Hay Hay Hay Hay Hay
Low risk across all factors if only taking sustainable
extraction. If displace animal feed, assume hay/silage
available locally
Bark, branches
and leaves EU
Low risk provided sustainable extraction limits are not
exceeded. Also benefit of less nitrate formation and
more attractive landscape if removing logging residues
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Feedstock Region Environmental Impacts Social impacts
Assumptions Species bio-
diversity
Landscape/
visual
Forest
regen. Soil Water
Food
security
Land
rights
Labour
rights Other
Saw-dust and
cutter shavings EU Wood Wood
Wood,
straw
Wood,
straw
Diverted from heat & power, panel & board, plus animal
bedding. Assume additional forest residues and straw
available locally
Black & brown
liquor EU Wood Wood Wood Wood
Mining
Transport
Diverted from heat & power, assume additional forest
residues available locally. Chemicals recycle back to the
mill has to be considered only if black liquor is
transported off-site for biofuels production
UCO UK Diverted from disposal of residual waste to landfill,
assumed collection of additional household resources
Animal fats (Cat I
and II) UK Wood Wood Wood Wood Diverted from heat & power
Miscanthus UK Variable Variable Variable Variable Transport New growth. Medium to high risks with ILUC impacts,
with scope for mitigation. Possible biodiversity benefits
Short rotation
coppice UK Variable Variable Variable Variable Transport
New growth. Medium to high risks with ILUC impacts,
with scope for mitigation. Possible biodiversity benefits
Short rotation
forestry UK Variable Variable Variable Variable Variable Transport
New growth. Medium to high risks with land impacts.
No resource before 2030
Small round-wood UK &
US Wood Wood Wood Wood
Low risk provided sustainable extraction limits are not
exceeded
Micro-algae US Variable Variable Transport New growth. Sensitive to climate, growing conditions
and water availability
Macro-algae UK Variable Transport New growth. Sensitive to climate, growing conditions
and water nutrients
Renewable
electricity UK Variable Transport New growth. Sensitive to location and technology
Waste carbon
gases EU Nat gas
Low risk from diversion from steel mill flaring. Diverted
from heat & power would increase natural gas use
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51
Price impacts of diversion
Based on the feedstock availability (both collected and uncollected), and the size and location of
competing uses, we present in Table 10 the potential price impacts of diverting feedstocks to biofuel
use. This has been carried out in a qualitative manner, using the following approach:
• Where the feedstock availability is capped, minimal additional resource can be collected, and
multiple competing uses already exist for a highly fungible/traded feedstock, the price and
knock-on impact of diverting feedstock to biofuels is likely to be high (inelastic supply). These
feedstocks include tall oil pitch, crude glycerine, grape marcs & wine lees, nut shells, husks,
along with sawdust & cutter shavings, and animal fats. Straw can also fall into this category,
depending on location and available additional resource.
• Other feedstocks have more modest levels of competition or additional sustainable supplies
that can be accessed for biofuels, hence the price impacts are not likely to be as high. These
feedstocks include MSW, C&I waste, bagasse, cobs, small round-wood and UCO.
• Where there still is a large uncollected resource potential that can be sustainably extracted,
and few competing uses for the existing feedstock volumes (or significant productivity gains
that can be made), then we have estimated that the price and knock-on impact of diversion
to biofuels is likely to be low (elastic supply). These feedstocks include empty palm fruit
bunches and forestry residues, along with the “new growth” feedstocks highlighted in green
in Table 10 (energy crops, short rotation forestry, algae and renewable electricity).
• Some feedstocks are rarely transported or traded, and although the feedstocks have a value
to their captive users, they do not have a visible market price – these “Not Applicable” price
impacts are shaded in grey in Table 10. This applies to feedstocks such as black & brown
liquor, waste carbon gases, palm oil mill effluent, along with the majority of animal manures
and sewage sludges. In these cases, diverting material to biofuels production is not
necessarily detrimental, since a higher value on the feedstock means that the industries that
generate these resources are then more economically competitive, and are also incentivised
to more efficiently treat and utilise the residues. Stakeholders have communicated that
instead of talking about price impact “risks”, it is more relevant to fully endorse further
recovery efficiencies and upgrading of resources – provided that these productivity
improvements are achievable. For example, if biomethane can be produced economically,
recycling valuable commodities via digestate from sewage sludge, thereby lowering the costs
of sustainable water management, this is a benefit to society and should not be named as a
risk. Similarly, the high efficiency production of biofuel from black liquor instead of achieving
modest efficiencies via electricity generation in a Tomlinson recovery system should be
welcomed instead of being presented as a risk to the wood pulping industry – however, this
does then come down to a discussion of the “best use of bioenergy” (which is outside the
scope of this study).
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Table 10: Summary of estimated price impacts. Note that price increases are not necessarily a risk or disadvantage, depending on what competing uses exist, and the
effect of promoting more efficient use of a resource. The competition levels are current estimates for the particular region considered.
Feedstock Region Growth in theoretical
potential? Additional sustainable collection?
Indicative current
competition in the
example region?
Of the competing
uses, what % are
energy uses?
Traded resource? Potential price
impact?
Bio-fraction of MSW UK Flat Large (landfill) 60% 40% Contract tie up Medium
Bio-fraction of C&I waste UK Flat Large (landfill) 40% 40% Contract tie up Medium
Straw UK Flat Perhaps limited (left on ground) 70-90% 5-10% Partially Medium-High
Animal manure UK Flat Large (spread) 15% 90% Minimal NA
Sewage sludge UK Small rise Limited (spread) 90% 100% Minimal NA
POME SE Asia Large rise Large (discharge) Low High No NA
Empty palm fruit bunches SE Asia Large rise Large (burning) Low Low Partially Low
Tall oil pitch EU Small rise Minimal 100% 100% Yes High
Crude glycerine EU Small rise Limited 90% 10% Yes High
Bagasse Brazil Large rise Large (burning) 60% 80% Partially Medium
Grape marcs EU Flat Minimal 100% 0% Partially High
Wine lees EU Flat Minimal 100% 0% Partially High
Nut shells EU Flat Minimal 100% 50% Yes High
Husks EU Flat Minimal 100% 50% Partially High
Cobs US Small rise Large (left on ground) 50% Low Partially Medium
Bark, branches, leaves EU Small fall Large (left on ground) 10% Low Partially Low
Sawdust & cutter shavings EU Small rise Minimal 100% Medium Yes High
Black & brown liquor EU Rise Limited 100% 100% No NA
UCO EU Large rise Medium (disposal) 10% 0% Yes Medium
Animal fats (Cat I and II) UK Small rise Minimal 70% 100% Yes High
Miscanthus UK New growth Large 0% NA Partially Low
Short rotation coppice UK New growth Large 0% NA Partially Low
Short rotation forestry UK New growth (>2030) Large 0% NA Yes Low
Small round-wood UK Flat Medium (left un-harvested) 30% 0% Yes Medium
Micro-algae US New growth Large 0% NA Yes in future Low
Macro-algae UK New growth Large 0% NA Minimal Low
Renewable electricity UK New growth Large 100% 100% Yes Low
Waste carbon gases EU Flat Medium (flare/venting mills) 50% 100% No NA
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The impact ratings in Table 10 are only estimates, since the true impact on pricing will be location
and policy specific, depending on supply cost curves as to how the new biofuel demand is met within
that feedstock’s market. In particular we note that the competing use percentages are indicative
only, based on the current feedstock flows given in Table 7, and therefore only apply to the example
regions considered (e.g. UK, EU or other world region of production). We have also included an
additional column to highlight where the competing uses as given in Table 7 are predominately in the
energy sector (i.e. heat and power), or where the competing uses are mainly animal feed, bedding,
industrial and material uses.
Taking the example of straw to illustrate this locational variation; the UK straw market is reasonably
tight, given only 7.4-11 Mt/yr judged by industry experts to be sustainably extractable (Ecofys, 2013;
HGCA, 2013), and 6.8Mt/yr of current competing uses. The competition factor for UK straw was
therefore judged at around 70-90%. However, based on Ecofys (2013) data, some EU countries have
very large sustainable straw resources that are up to 50% underexploited (e.g. France, Germany),
whilst other countries have a straw deficit (e.g. Poland and Netherlands have demands than cannot
be sustainably generated each year). Across the whole of Europe, the competition factor for straw in
Table 10 could be estimated at nearer 75%, not 70-90% as in the UK. We therefore emphasise that
the sustainable collected potentials, less competing demands, will be different in each region
considered – but that these volumes once known are the potential feedstock resource that is
available for biofuel production without a risk of indirect effects.
As noted previously, this analysis for clean straw is separate for the analysis of animal manures (with
the recycling of a large proportion of used straw back to fields). Any diversion into biofuels of straw
currently used for animal bedding would require an additional material (sustainable extraction of
more straw or wood) to be found to house the livestock, or a change in agricultural practices.
Depending on the soil quality and nitrate vulnerable zones, replacement sources of nutrients and
organic matter may also be required to maintain the soil quality in local fields (hence use of fertiliser,
peat or digestate). It is therefore valid to identify the proportion of straw used for animal bedding as
being a competing use versus biofuels (or other energy) production, and not counting this animal
bedding proportion as being part of the sustainably extractable resource.
4.7 Direct GHG emissions
In this section, we have provided estimates of the direct GHG emissions associated with each biofuel
supply chain, using either current actual UK data (where this exists) or the RED calculation
methodology for future chains without current data. The purpose of providing these indicative values
is not to calculate the exact % saving (or to say what the RED should adopt as new typical values) –
especially since there may be wide ranges in values due to different regions, supply chains, feedstock
and conversion technology variations.
It is rather to understand, together with the feedstock potential, the relative importance of different
feedstocks in terms of emissions savings – and whether it is likely that the biofuels produced from
the available feedstock will have very low direct GHG emissions, or be closer to the RED thresholds.
These indicative GHG savings will also be combined with the production costs to calculate estimates
of the cost per tonne of CO2 saved (£/tCO2) for each of the biofuel routes.
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4.7.1 Methodology
UCO biodiesel, animal fat biodiesel and bio-methanol from crude glycerine are currently consumed in
significant volumes within the UK. The RTFO unit collects annual carbon and sustainability data;
hence for these three Annex IX biofuel chains we have used the latest DfT (2013) average actual data.
The RED then provides a selection of typical and default values for wheat straw (to ethanol), waste
wood and farmed wood (to ethanol, FT diesel, DME and methanol), along with MSW and manure (to
compressed natural gas via biogas). These advanced biofuel routes match several of those selected in
this study – in these cases we have therefore used the RED typical values as the direct GHG emissions
associated with these routes. See Section 4.4.1 for the choice of biofuel route analysed for each
feedstock – and note that these are not the only biofuels allowed (as shown in Figure 4, many
feedstocks have multiple available routes). The typical values are used rather than the default
emission values, as the typical emissions do not include the conservative factor (i.e. the 40% uplift on
conversion steps), and therefore better represent what could be the most likely emissions from each
of the biofuel supply chains.
Where a biofuel route considered in this Annex IX study does not exactly match any of those listed in
the RTFO data or the RED, we have adopted the following approach:
• If the biofuel route is sufficiently similar to a route in the RED, then this RED chain is used as
a proxy to give indicative typical emissions. E.g. the bio-fraction of C&I waste to biomethane
chain is assumed to be the same as the bio-fraction of MSW to biomethane chain.
• If the biofuel route shares some similarities to a route listed in the RED, but with a different
geographical location for the biofuel production, we have adapted the typical emission value
given for the RED route by adding in the estimated impact of the missing transport distance.
For example, there is no corn stover ethanol value in the RED, but the existing wheat straw
ethanol value can be adapted by adding an extra biofuel shipping step from the US to the EU.
• Many of the feedstocks on the list are wastes or residues, and are therefore considered to
have zero GHG emissions associated with the production of the feedstock. In these cases, the
GHG calculations for these routes can be based on the existing RED typical values for other
chains that produce the same biofuel, but excluding the upstream feedstock production
steps. Each of the typical values has a breakdown of emissions associated with cultivation
and harvesting, transport, conversion and downstream distribution. We therefore exclude
the emissions from cultivation and harvesting steps, in order to derive the GHG emissions
associated only with conversion and distribution. Transport steps can also be excluded if the
feedstock is assumed to be available at the conversion plant (no transport needed). For
example, tall oil pitch to HVO is based on the rapeseed HVO typical value, but only
considering the emissions from conversion to HVO and downstream distribution – excluding
all the rapeseed cultivation, oil extraction and transport emissions.
• Some of the biofuel routes are significantly different to those listed in the RED, especially
those using feedstocks defined as products (i.e. upstream emissions have to be calculated).
In these cases, it was not possible to follow the same approach as above by adapting the
emissions associated with any of the RED fuel chains – hence external references and
internal E4tech data developed during other assignments have been used instead. Most of
the Part C feedstocks fall into this category.
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The approach above has been followed to ensure methodological consistency has been applied as far
as possible across the different chains. Specific assumptions relating to the calculation of the
emissions for each biofuel chain are provided in Table 11, along with the key sensitivities.
Typical European values
Note that for the calculations of indicative GHG emissions and production economics, the Annex IX
biofuels in this study are not considered to all be transported to one particular place, e.g. the UK.
Instead, the same approach is taken as in the RED typical value calculations, which is to assume that
the finished biofuel will always be consumed within the EU (exact location unspecified). If the biofuel
is produced within the EU, then the typical values usually assume 150km of road transport from the
point of its production to the point of use. Given that the UK is part of the EU, we assume that if the
biofuel is produced within the UK, it will also be consumed within the UK (after 150km of road
transport). However, if the biofuel is produced outside the EU, it requires shipping into the EU, with
150km of road transport then assumed from where the biofuel is landed at an EU port.
The GHG emissions provided in Table 11 in are therefore consistent with the most likely locations of
advanced biofuel production and consumption across the EU – i.e. typical European values. Also
note that the feedstocks are usually converted to biofuel in the same country as their point of
production – there is no requirement that all the feedstocks be transported to one particular place
before conversion (e.g. the UK). In other words, the calculations for each chain do not assume that
the advanced biofuel plant has to be located in the UK – the advanced biofuel plant is only located in
the UK if the feedstocks are also assumed to be produced in the UK.
If locating an advanced biofuel plant in the UK is a requirement, in order to calculate the emissions
associated with this biofuel production, it would be necessary to consider whether additional
transport steps would be required to import any feedstocks, and calculate the GHG emissions of the
specific chains being considered. These added steps could add considerably to the emissions and
costs of routes where the feedstock has low volumetric or energy density, i.e. high transport costs.
Many of the Annex IX feedstocks are highly unlikely to be imported into the UK for this reason – e.g.
MSW, industrial waste, manure, sewage sludge, POME, wine lees, black & brown liquor, macro-algae
and waste carbon gases. Some feedstocks are only likely to be imported if in a dry pelleted form,
such as straw, corn stover, cobs, EPFBs, bagasse, grape marcs, husks, bark, branches & leaves.
Woody feedstocks could be imported in pellet or chip form, such as saw dust & cutter shavings,
Miscanthus, SRC, SRF and small round-wood. The remaining feedstocks are more likely to be readily
traded, due to their high energy and volumetric density, such as tall oil pitch, crude glycerine, nut
shells, UCO, animal fats and micro-algae oils.
Fossil fuel comparator
As laid down in the RED, ‘biofuels’ means liquid or gaseous fuel for transport produced from biomass.
Communication 2010/C 160/02 states that “The fossil fuel comparator to be used at present for
biofuels is 83.8 g CO2-eq/MJ. This value will be superseded by ‘the latest actual average emissions
from the fossil part of petrol and diesel in the Community’ when that information becomes available
from the reports submitted under the Fuel Quality Directive”
These definitions and guidance therefore mean that gaseous fuels such as biomethane and
renewable hydrogen from Annex IX feedstocks are to be compared against the same fossil petrol and
Advanced Biofuel Feedstocks - An Assessment of Sustainability
56
diesel baseline as all other liquid biofuel routes. We note that this is also the approach taken by the
RTFO, in correctly implementing the RED in the UK.
In reality, biomethane would most likely be displacing natural gas (at ~68.0 gCO2e/MJ), and
renewable hydrogen would most likely be displacing hydrogen from steam methane reforming (at
~87.9 gCO2e/MJ). However, the above RED rules mean that the AD routes and renewable electrolysis
routes in Annex IX should still be compared against a fossil petrol and diesel baseline of 83.8
gCO2e/MJ. This baseline value may be increased to 90.3 gCO2e/MJ by 2020, as proposed in the
Impact Assessment accompanying the Oct 2012 RED and FQD proposals (European Commission,
2012). As well as not reflecting the differences in carbon intensity of the displaced fossil fuels, this
approach of calculating GHG savings at a common fuel level also has a further shortcoming in that it
does not consider the tank-to-wheel efficiency of the vehicle, which can be considerably different for
liquid internal combustion engines, hydrogen fuel cells and compressed natural gas drive trains.
Calculating GHG savings per kilometre driven (the actual service demanded) would potentially be a
more robust methodology, however, this is beyond of the current study. Similarly, a discussion of
infrastructure and engine compatibility with regards to fuel blends, and the impact this may have on
the volumes of each fuel demanded, is also out of scope – see E4tech (2013b).
Finally, the cost of GHG emissions savings (given in £/tCO2e saved) are based on the biofuel
production costs presented in Table 6, taking the difference between fossil prices and biofuel costs
(£/GJ), and dividing by the difference in GHG emissions (gCO2e/MJ). The results shown in the final
column of Table 11 are an indication of which biofuel routes are the most cost efficient method of
reducing GHG emissions.
We note that the fossil prices are based on Natural gas = £9.8/GJ, fossil hydrogen (from steam
methane reforming) = £26.8/GJ, with fossil petrol and diesel = £18.9/GJ, so whilst the GHG
comparator might be the same, the price comparator is allowed to differ. For information, the fossil
fuel energy densities used are Natural gas = 46GJ/t, Fossil hydrogen = 120GJ/t, Liquid fossil petrol
and diesel = 44GJ/t.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
57
Table 11: Summary of direct GHG emissions, assumptions and sensitivities
Feedstock Fuel Region GHG emissions
(gCO2e/MJ) Assumptions Key sensitivities
% GHG
saving
Cost of GHG
saving (£/tCO2e)
Bio-fraction of
MSW Bio-methane UK 17
RED typical value for MSW biomethane. We note that
UK actual data is thin, but reports at 31gCO2e/MJ C intensity of electricity (major input) 80% 120
Bio-fraction of
C&I waste Bio-methane UK 17 Proxy of RED typical value for MSW biomethane C intensity of electricity (major input) 80% 138
Straw LC ethanol UK 11 RED typical value for wheat straw ethanol Ammonia & lime inputs to conversion
step. Assumed enzymes made onsite 87% 104
Corn Stover LC ethanol US 16 Assume same as RED typical value for wheat straw
ethanol, but with extra shipping step from US to EU
Ammonia & lime inputs to conversion
step and transport distances 81% 178
Animal manure Bio-methane UK 13 RED typical value for manure biomethane C intensity of electricity (major input) 84% 406
Sewage Sludge Bio-methane UK 13 Proxy of RED typical value for manure biomethane C intensity of electricity (major input) 84% 240
Palm oil mill
effluent Bio-methane SE Asia Not considered as biogas from POME used in local markets and not exported to EU
Empty palm
fruit bunches FT diesel SE Asia 10
Assume same as RED typical value for waste wood FT
diesel with extra shipping step from Indonesia to EU
Transport distances and modes.
Conversion step emissions (0 in RED) 88% 109
Tall oil pitch HVO EU 9
Assume same as RED typical value for rapeseed HVO,
but without feedstock production emissions, plus
extra shipping from Scandinavia to Rotterdam
Hydrogen requirements and means of
hydrogen production 90% 12
Crude glycerine Methanol EU 25 UK RTFO average data Conversion step natural gas use 70% 331
Bagasse LC ethanol Brazil 23
Assume same as RED typical value for farmed wood
ethanol, plus extra trucking in Brazil and shipping to
EU, but without emissions from cultivation &
transport
Ammonia & lime inputs to conversion
step. Transport distances and modes 73% 86
Grape marcs LC ethanol EU 11
Assume same as RED typical value for wheat straw
ethanol (no emissions associated with production of
feedstock)
Ammonia & lime inputs to conversion
step 87% 266
Wine lees 1G ethanol EU 20
Assume same as RED typical value for sugarbeet
ethanol, but without emissions from cultivation and
transport
Natural gas use for drying in conversion
step 76% 173
Nut shells FT diesel EU 4 Proxy of RED typical value for waste wood FT diesel Conversion step emissions (0 in RED) 95% 138
Husks LC ethanol EU 11 Emissions as per wheat straw ethanol (no emissions
associated with production of feedstock)
Ammonia & lime inputs to conversion
step 87% 196
Cobs LC ethanol US 16 Assume same as RED typical value for wheat straw
ethanol, but with extra shipping step from US to EU
Ammonia & lime inputs to conversion
step and transport distances 81% 246
Bark, branches,
leaves FT diesel EU 4 RED typical value for waste wood FT diesel Conversion step emissions (0 in RED) 95% 94
Advanced Biofuel Feedstocks - An Assessment of Sustainability
58
Feedstock Fuel Region GHG emissions
(gCO2e/MJ) Assumptions Key sensitivities
% GHG
saving
Cost of GHG
saving (£/tCO2e)
Saw dust &
cutter shavings FT diesel EU 4 RED typical value for waste wood FT diesel Conversion step emissions (0 in RED) 95% 155
Black & brown
liquor Bio-DME EU 1
Assume same as RED typical value for farmed wood
DME, but without cultivation, chipping and transport
steps
Conversion step emissions (0 in RED) 99% 159
UCO FAME UK 15 UK RTFO average data for UCO biodiesel Methanol input to conversion step 82% 96
Animal fats Cat
I & II FAME UK 15 UK RTFO average data for waste tallow biodiesel Methanol input to conversion step 82% 12
Miscanthus LC ethanol UK 11
Assume same as RED typical value for wheat straw
ethanol, replacing cultivation & transport emissions by
those of Miscanthus bales from UK solid biomass
carbon calculator
Cultivation inputs (diesel for plant &
harvest, fertilisers). Achievable yields
uncertain. Ammonia & lime inputs to
conversion.
87% 107
Short rotation
coppice FT diesel UK 6 RED typical value for farmed wood FT diesel
Achievable yields uncertain. Conversion
step emissions (0 in RED) 93% 178
SRF/small
round-wood FT diesel UK 6 RED typical value for farmed wood FT diesel Conversion step emissions (0 in RED) 93% 157
SRF/small
round-wood LC ethanol US 20 RED typical value for farmed wood ethanol
Ethanol yields, ammonia & lime inputs
to conversion step, transport distances 76% 187
Micro-algae FAME US 31-36
Based on analysis done for the Carbon Trust in 2011.
These emissions represent a best available current
technology scenario in US Gulf coast
Energy input intensity, algal oil yield
and biomass productivity. Unclear if low
GHG algae can be commercially mass
produced
58-63% 786 – 859
Macro-algae Bio-methane UK 17-34 DfT Modes 2 (2050 figure). Based on cultivation
emissions and biogas yield from Ecofys (2008)
Biomass yield of macro-algae and
harvesting energy. As not commercially
produced yet, GHG savings uncertain
60-80% 809 – 1,085
Renewable
electricity Hydrogen UK 9
Based on JEC WTT analysis, appendix 2. Wind power
with central electrolyser supply chain
Hydrogen compression and transport
mode 89% 376
Waste carbon
gases Ethanol EU 25
Based on lower bound of emissions estimated for
Lanzatech’s steel mill gas to ethanol (Jain, 2013)
Power and steam inputs to conversion
process 70% 62
Advanced Biofuel Feedstocks - An Assessment of Sustainability
59
Table 11 shows that biofuel emissions for Annex IX feedstocks can vary from as little as 1 gCO2e/MJ
up to ~36 gCO2e/MJ. However, the actual emissions value achieved for a particular route is
dependent on a couple of key factors:
• The emissions associated with cultivation. Micro- and macro-algae in particular have fairly
significant cultivation emissions, due to the energy expended in growing, harvesting and
extraction. All waste and residue feedstocks are assigned zero emissions by the RED, but IEEP
(2013) and ICCT (2013) both note that this ignores the possible impacts on soil carbon stocks
as the extraction of agricultural or forestry residues increases, plus emissions from additional
fertiliser use to replace lost nutrients, and hence advocate an extension of methodology
system boundaries to calculate these impacts. However, there is unlikely to be sufficient
long-term data on the initial and annual soil carbon changes to allow this impact to be
accurately quantified – leading research in the UK is still ongoing in this area with the ETI’s
Ecosystem Land Use Modelling & Soil C GHG Flux Trial (ELUM) project.
• The level of chemical inputs into the conversion plant. FT plants are assumed to have no
chemical inputs (hence no emissions), whilst the LC ethanol plants have large inputs of
ammonia, lime, sulphuric acid, and ammonia sulphate for pre-treatment and fermentation.
This is the main difference between the value of 4 gCO2e/MJ for waste wood FT diesel (e.g.
bark, branches, leaves), and the value of 11 gCO2e/MJ for waste wood ethanol (e.g. husks).
However, one stakeholder noted that currently there is no methodological allocation for co-
products in the RED selection of typical and default values for lignocellulosic ethanol routes,
despite the significant potential for exploiting the residual material left after extraction of
carbohydrates and sugars from the cellulose component.
• The level of energy inputs into the biofuel conversion plant. FT diesel and LC ethanol plants
are assumed to be self-sufficient for energy, whereas biomethane plants require input
electricity for gas compression (with GHG impacts then set by the grid carbon intensity).
Crude glycerine also requires significant natural gas input for cracking into syngas.
• Minimising transport distances. Road trucking in Brazil and shipping ethanol to the EU adds
~9 gCO2e/MJ to the bagasse route selected, whereas shipping FT diesel from SE Asia is
assumed to add ~6 gCO2e/MJ to EPFBs.
The GHG emissions seen for each route are therefore partially set by the feedstock and location of
production, and partially set by the choice of biofuel conversion technology and configuration. It is
not possible to produce a normalised GHG emissions factor for a common biofuel across all the
feedstocks, since there is no single technology capable of utilising every feedstock – i.e. inherent
within each feedstock is a choice of technologies (as in Section 4.4), and hence GHG emissions.
All routes are able to save at least 70% (many routes are around 90%), with the exceptions of micro-
algae and macro-algae, which are around the 60% threshold (using the current comparator).
Technical innovation in these algae routes aiming at improving production costs, by improving yields
and reducing energy inputs, will also lead to lower GHG emissions being realised. Ethanol from waste
carbon gases is only at ~70% GHG savings – and whilst renewable hydrogen is likely to be very low
emissions, it is important to note that most of the Parliament’s Part C feedstocks proposed for
quadruple counting actually have higher GHG emissions than most of the single count Part A or
Advanced Biofuel Feedstocks - An Assessment of Sustainability
60
double count Part B feedstocks. Were the multiple counting lists only to be based on GHG savings,
then algae and carbon capture and utilisation should be receiving the least support, not the most.
None of the selected routes analysed in this study are cheaper than their fossil fuel comparator.
However, the most cost efficient routes (those with <£100/tCO2e saved) are animal fats, tall oil pitch,
bagasse, waste carbon gases, forestry residues and UCO. Many other routes lie in the bracket £100-
300/tCO2e saved, with more expensive routes being crude glycerine and renewable electrolysis (both
mainly due to feedstock costs), and animal manures (due to small scale AD and upgrading costs). As
expected, algae are the least cost efficient routes (approaching 900/tCO2e saved), due to their high
current production costs and modest GHG savings.
4.8 Holistic view
In this section we pull together an overview of the whole list, based on analysis conducted in the
basic information, supply, technology, economics and sustainability sections above. We have
collected and compared the following key criteria in Table 12:
• Global 2020 feedstock supply – based on Table 4. These feedstock potentials are based on
the 2020 supply potentials, converted into PJ/yr of biofuel – but do not consider biofuel plant
capacity constraints, or competing uses. Green is for >1,000 PJ/yr (wastes, straw, manures,
wood and renewables), Orange for 100-1,000 PJ/yr (UCO, animal fats, other agric. residues)
and Red for <100 PJ/yr (energy crops, algae).
• Feedstock price - based on Table 5. The (*) AD routes show their £/t price converted in terms
of theoretical biomethane yields. Waste resources with a gate fee have a negative price, and
those energy dense feedstocks (like tall oil pitch, crude glycerine, UCO and animal fats) have
the highest prices – along with algae and renewable power.
• Biofuel production costs – based on Table 6. For the selected delivered biofuel routes, with
Green for <£25/GJ, Orange for £26-40/GJ, and Red for >£40/GJ.
• Key competing uses – based on Table 7. A summary of the main existing sectors, with red
highlighting those substitute resources that have a high carbon or ILUC risk. Energy crops and
short rotation forestry have their land use highlighted
• Potential price impacts - based on Table 10. Those feedstocks with minimal expansion
potential and high competition levels are likely to experience price increases if diverted to
biofuels. Those feedstocks with a more elastic supply, and lower likely price impacts include
feedstocks being grown specifically for biofuels, or wastes with fewer competing uses.
• % GHG savings – based on Table 11. Most routes are able to achieve above 80% (Green).
Routes using MSW, C&I waste, bagasse, crude glycerine, wine lees, algae and waste carbon
gases are more likely to fall into the 60-80% bracket (Orange), due to cultivation emissions,
chemical or energy inputs, and transport distances.
• Cost of GHG saving – based on Table 11. Combination of low costs and high GHG savings
leads to the lowest cost options for saving GHG emissions.
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61
Table 12: Summary of key criteria (Red = Least attractive, Orange = Medium, Green = Most attractive)
Feedstock LHV
(GJ/t)
Global 2020
feedstock pot.
(PJbiofuel/yr)
Feedstock
price (£/GJ)
Biofuel
production
cost (£/GJ)
Key competing uses and substitute resources
Potential
price
impact?
% GHG
savings
Cost of
GHG saving
(£/tCO2e)
Bio-fraction of MSW 6.3 3,253 -6.5* 18 Landfill (none), H&P (nat gas, chip), compost (fert, peat, digest.) Medium 80% 120
Bio-fraction of C&I waste 7.0 2,390 -5.9* 19 Landfill (none), H&P (nat gas, chip) Medium 80% 138
Straw 15.0 5,240 2.8-4.2 26-31 Soil (extract sust), animal feed (hay), bedding (wood) Med-High 81-87% 104-178
Animal manure 1.3* 12,016 0.0* 39 Spreading to land (digestate) NA 84% 406
Sewage sludge 0.5* 301 0.0* 27 AD & incinerate (nat gas), spread (digestate) NA 84% 240
Palm oil mill effluent 0.8* 127 0.0* No import Open pond discharge (none) NA
Empty palm fruit bunches 4.5 172 0.7 27 Burning (none), H&P (nat gas, chip), compost (fert, peat) Low 88% 109
Tall oil pitch 38.0 17 11.1 20 H&P (HFO, chip) High 90% 1
Crude glycerine 14.2 42 17.9 38 Refining (fossil), H&P (HFO, chip), animal feed (sugar, corn) High 70% 331
Bagasse 7.8 1,748 1.1 24 Burning (none), H&P (extract sust trash) Medium 73% 86
Grape marcs 7.8 20 9.4 38 Wine (more grape), compost (fert, peat, digest.) High 87% 266
Wine lees 6.2 5 9.4 30 Wine (more grape), compost (fert, peat, digest.) High 76% 173
Nut shells 16.4 61 4.1 30 H&P (coal, wood, straw) High 95% 138
Husks 13.0 645 7.5 33 H&P (coal, wood, straw) High 87% 196
Cobs 12.4 185 4.6 36 Soil (extract sust), animal feed (hay) Medium 81% 246
Bark, branches, leaves 12.4 1,376 3.1 26 Soil (extract sust) Low 95% 94
Sawdust & cutter shavings 15.2 614 4.4 31 H&P, bedding, paper, panel (all more wood, straw) High 95% 155
Black & brown liquor 12.0 1,714 9.3 32 H&P (HFO, chip) NA 99% 159
UCO 36.0 266 20.1 25 Household disposal (none) Medium 82% 96
Animal fats (Cat I and II) 32.7 119 15.6 20 H&P (HFO, chip) High 82% 12
Miscanthus 13.4 24 4.0 27 New growth assumed (agric. land) Low 87% 107
Short rotation coppice 12.3 47 4.0 33 New growth assumed (agric. land) Low 93% 178
Short rotation forestry 12.3 0 3.5 31 New growth assumed (land) Low 93% 157
Small round-wood 12.3 3,282 2.6 31 Soil (extract sust), paper & panel (more wood) Medium 76-93% 187
Micro-algae 36.0 1 47.5 60 New growth assumed (barren land) Low 58-63% 809 - 859
Macro-algae 2.0* 2 23.8* 64 New growth assumed (coastal seas) Low 60-80% 786 – 1,085
Renewable electricity NA 17,316 26.4 55 New growth assumed (wind-farm, solar PV) Low 89% 376
Waste carbon gases 6.2 511 6.7 23 Flare (none), H&P (nat gas) NA 70% 62
Energy densities marked with * are based on theoretical biogas yields, not the Lower Heating Value of combustion (which would be negative, given the high moisture contents)
Nat gas = natural gas, chip = wood chip, sust = sustainably, HFO = Heavy fuel oil, fert = fertiliser, H&P = heat & power, agric. = agricultural, digest. = digestate
Advanced Biofuel Feedstocks - An Assessment of Sustainability
62
5 Analytical framework for assessing feedstocks
During this study, we have developed a structured framework to assess different feedstocks (Annex
IX or otherwise) that are proposed to benefit from additional regulatory support. Based on the set of
key criteria developed in the sections above, we have developed a hierarchy of questions, which can
be used to determine whether or not a particular feedstock meets the criteria required to be eligible
for additional support. We note that meeting the current RED is a minimum entry requirement.
These questions cannot be used to assess whether a certain batch of material available for purchase
will lead to a multiple counting biofuel. Rather, these questions are intended to be used to assess
whether a certain feedstock should be eligible for additional support, alongside performing a more
detailed market analysis on the material type under consideration, including where all the different
sources of the material arise from, and all its alternative uses.
This analytical framework is illustrated as a flow diagram in Figure 6. The main steps are as follows:
1. Is the material classified as a waste, processing residue, agricultural or forestry residue, co-
product or product? If a waste or processing residue, skip to Step 3, otherwise continue to
Step 2.
2. Does it come from land with high biodiversity, or has the status of the high carbon stock land
or peat land utilised changed since 2008? If Yes, then the material should not be eligible
under the RED, let alone multiple counting (STOP). If No, continue to Step 3.
3. What are the key competing uses – i.e. what would otherwise happen to the material if not
used for biofuels production? This requires thinking about the overall feedstock resource as a
whole, and which uses are the most important (and whether these competing uses are able
to utilise all the available material or only a specific smaller proportion). If several uses are
important, then different proportions of the material should follow the different decision
tree branches and be judged separately. Ultimately the question for this step is: if the
feedstock already has an existing use, are there likely and desirable alternative options for
that existing use, were the feedstock to be diverted to biofuel production?
a. Fractions that are landfilled, discharged or open burning (i.e. without energy
recovery), then use of this material for biofuels production is a better use under the
Waste Hierarchy – continue to Step 4
b. The feedstock would not be grown. If this is the case, then is there significant risk of
ILUC associated with growing the feedstock on the land types chosen (e.g. via food
competition), which cannot be mitigated? If so, the feedstock should likely not be
incentivised, as it does not provide a low risk solution to GHG savings (STOP).
Proceed to Step 3c only if ILUC can be avoided or mitigated to an acceptable level –
e.g. via a combination of: use of land not in competition with food, promoting
beneficial use of co-products, protecting high carbon stock land, above baseline yield
increases, supply chain efficiencies and farming system integration (E4tech, 2011).
c. The material would not be collected. In which case, can the collection be carried out
sustainably, i.e. extraction limits obeyed? If so, then continue to Step 4. If not, STOP.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
63
d. Fractions of the material are a direct input to food or animal feed. In which case,
ILUC risks for this fraction of the resource are likely to be too high, and hence
diverting this fraction of the material should not be supported (STOP). Importantly,
this STOP decision does not necessarily apply to the whole feedstock resource – it
only applies to the proportion used in food or animal feed. We note that the animal
feed market is highly complex, and further in-depth analysis is likely to be required to
determine exactly which feedstock fractions are being used in these markets (or
which feedstock fractions cannot be used, due to e.g. contamination, prohibitively
expensive testing).
e. Fractions of the material are used for energy, industrial or material applications. In
these cases, does the substitution analysis conducted in Section 4.6 show that there
is a significant risk from diverting material to biofuels? If significant productivity gains
are not possible to offset this diversion, do the substitute resources required in these
competing uses have detrimental carbon, cost, land, environmental or social
impacts? If so, then STOP, otherwise continue to Step 4
f. Fractions of the material would be re-used, recycled or composted. In these cases,
the material should only be taken to biofuels production if the same services as
previously can be provided whilst doing so – if not, STOP. This mainly applies to AD
feedstocks which could return PASS110 certificate digestate to fields in order to still
classify as recycling. We note that the Waste Hierarchy usually categorises biofuels
production as an energy recovery, below these re-use, recycling or composting uses
– hence this could be a barrier. However, the Waste Hierarchy allows for deviation if
demonstrable economic or environmental benefits can be shown – e.g. AD has
better GHG savings than composting. Provided this is the case, proceed to Step 4
4. Are the lifecycle GHG emissions savings of producing biofuel from the material high enough
(versus a suitable fossil comparator) to be supported? If likely less than 60%, then the biofuel
would not be eligible under the RED limits, hence STOP. If above a certain threshold, e.g. 70%
or 80% GHG savings, proceed to Step 5. If between 60% and the threshold, then need to
assess likelihood that the GHG emissions could improve in the future, and whether the
current levels of GHG savings are likely to be acceptable in only the short-term, or are
acceptable longer-term (depends on energy system modelling and decarbonisation
requirements between energy sectors). If acceptable, proceed to Step 5.
5. Would use of the material for biofuels production be economically viable without support,
and hence likely to be deployed? Or would deployment only occur with additional support,
due to, for example, the lack of commercial readiness of the conversion technology – and
hence support (of some appropriate form) is required to bring the technology up a few TRL
levels? Alternatively, is investment required in infrastructure to increase collection volumes
and supply chain efficiencies? Finally, does the route provide cost effective GHG savings –
e.g. a particular route from a material may be more expensive, but offers very high GHG
savings and low ILUC risks, hence is worth supporting. These questions are not necessarily
leading to STOP commands, but rather determining the type and level of support that might
be appropriate, given that the rest of the decision tree has determined there are low risks
and large benefits of using the material for biofuels.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
64
This list of criteria and questions characterise feedstocks that should be eligible for support. This list
has been through several iterations and changes in the course of the project, with the information
collected in the course of the study being used to help refine the framework and test its robustness.
It is important to note how sustainability risks are affected by the different potential levels of
volumes mobilised, the potential for additional resource beyond existing competing uses, the
potential for releasing additional resource via efficiency gains, and the level (and potentially order) at
which various competing uses will be impacted. Some wastes and residues (e.g. straw, forest
residues) may be considered sustainable as long as their mobilisation is contained within certain
limits and volumes, but risks may multiply if mobilisation goes beyond such limits. Local or regional
effects may also be important, since biofuel plants will typically be built where there is surplus
resource, even if there is demand in other countries or regions.
The flow diagram in Figure 6 is not intended to be read as a binary decision making mechanism – the
heterogeneity of each feedstock needs to be carefully considered, and any support could only be
provided up to a certain level of resource use (excluding certain higher risk portions). However,
maintaining this subtlety will require carefully implementation into any policy mechanism, to avoid
over-simplifying and setting up blanket bans on whole feedstocks. This study has helped identify for
which feedstocks sustainability risks are a concern for the majority of the feedstock resource base,
and those feedstocks where the sustainability risks are low.
The analysis in this study is time specific, and some of the alternative uses, replacement resources
and risks etc. may change in the future – several of the markets considered are dynamic and will
react to whether or not there are excesses/shortages in other markets. However, the decision tree
has been designed to still be relevant in the future; feedstocks only require re-evaluation against the
criteria when newer or better data becomes available.
Although understanding supply potentials helps prioritise which feedstocks require the highest
quality data or deserve further research – the supply potential of a feedstock does not necessarily
have to be used as an exclusion criteria in this framework. Niche volume feedstocks could still
provide benefits provided they meet the criteria, and could also be used as mixed feed input to
biofuels plants with other larger streams. There is minimal opportunity cost associated with keeping
these feedstocks on the list, and it may also help promote innovation in different routes. We
therefore recommend that smaller resources are not prevented from being assessed, i.e. a minimum
supply threshold is not set as a criteria.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
65
Figure 6: Flow diagram for the analytical framework, showing the choices and risks to be considered
Yes
No
YesNo
NO
SUPPORT
FOR THESE
ROUTES
NoNoYes
% not
collected
No = processing residue
Competing uses
What are the current material flows into each competing use? What would otherwise happen to the material - if not used as a feedstock for
biofuels production?
% re-use, recycling or
composting
% landfill,
discharge,
open burn
GHG emission savings
Are the GHG emission savings associated with biofuel production (using most l ikely supply chain) above a desired threshold? e.g. >60% vs. fossil baseline?
NB: All wastes and residues have zero GHG emissions up to the point of collection. Products & co-products allocate these upstream GHG emissions based on energy
content
Is there a significant risk from diverting
the material out of these sectors? I.e.
productivity gains cannot offset the
diversion, and replacement options are
high carbon, high cost, land using or
have determental biodiversity, other
environmental or social impacts?
% used for energy ,
industrial & material
applications
Yes = waste
Viability
Additionality: Would the biofuel route only be economically viable with support? (i .e. the feedstock &
technology would not be deployed without incentives; AND
Does the route provide cost-effective GHG savings that merit further support over other options?
SUPPORT NOT
NEEDED
Yes
SUPPORT
JUSTIFIED
Is there a significant risk that
growing the feedstock on the
land type chosen wil l cause
indirect land use change (ILUC),
i .e. food pressures, and/or
conversion of high-carbon land
to occur elsewhere globally?
No
Yes
No = product/co-product
Is it a waste?
A material which the holder discards,
intends to discard, or is required to
discard? AND has not been
purposefully mixed with other
materials in order to become a waste
No
Yes = residue
Is it an agricultural, aquaculture, fisheries or forestry
residue? i.e. those residues generated in connection
with cultivation, harvest, thinning, peeling or fell ing
Yes
START
Is it a residue?
Production of the material i s NOT the primary aim of the process; AND
The material is NOT a considerable/essential outcome of the process in the case that the material has uses
other than for energy; AND
The process has NOT been deliberately modified to produce a larger quantity or another quality of the
material (at the expense of the main product)
No
Can biofuel be made whilst providing
the same services? e.g. dewatered AD
digestate certified to PAS110 can meet
(or exceed) the same demands as the
raw feedstock, with better GHG
savings than composting - and both
would count as recycled material
% used for
food or
animal feed
NO
SUPPORT
FOR THIS
FRACTION
No
Is growing/
collecting this
material l ikely to
result in
unacceptable
environmental or
social impacts?
Yes
Land criteria
Is it l ikely to come from land with high
biodiversity value, high carbon stock or
peat land (as defined in the RED)?
% not
grown
Yes
NO
SUPPORT
FOR THIS
FRACTION
NO
SUPPORT
FOR THIS
FRACTION
NO
SUPPORT
FOR THIS
FRACTION
NO
SUPPORT
FOR THIS
FRACTION
NO
SUPPORT
FOR THIS
FRACTION
Advanced Biofuel Feedstocks - An Assessment of Sustainability
66
5.1 Recommendations for the Annex IX lists
This final section provides a preliminary assessment of each of the current Annex IX feedstocks
against the developed analytical framework to determine which justify additional policy support. This
analysis has been carried out based on the data collected and displayed above in Section 4, with the
results of this analysis displayed in Table 13.
The material classifications are as given in Table 3, with the exception of bagasse and nut shells,
which although the RED currently lists as agricultural residues, are more correctly processing residues
of downstream industrial plants. In the indirect risks column, we give the most likely substitute
resources that have sustainability issues, and hence require avoiding. We are not providing a
complete list of unacceptable substitutions, i.e. substitute resources that are not listed in Table 3 are
not necessarily acceptable. For example, if only heavy fuel oil in heat & power is listed as an indirect
risk for a feedstock, using coal or natural gas instead would have similar risks of increasing fossil fuel
emissions – but as these different fuels have been judged less likely to be substituted, for brevity we
have not included them.
Table 13 presents some of the key findings of this Annex IX study:
• Several feedstocks have a significant uncollected resource that could be diverted from
current disposal, produced without indirect impacts, or sustainably extracted with limited
competition. MSW, C&I wastes, manures, forest residues, small round-wood, algae and
renewable electrolysis are likely to need further support to be economically viable or help
commercialise conversion technologies. UCO may not require additional support, depending
on infrastructure investments to access domestic supplies.
• Some feedstocks face higher levels of competition, and hence only a smaller unused fraction
of the total supply is likely to be at low risk of causing indirect impacts. This includes straw,
cobs, sewage sludge, bagasse, empty palm fruit bunches and waste carbon gases.
• For other feedstocks, such as animal fats, nut shells, husks, sawdust & cutter shavings, tall oil
pitch, brown & black liquor, support should only be provided if the industries involved can
show replacement of the missing energy demands with low carbon, sustainable alternatives
– otherwise there is a risk of increased fossil fuel use offsetting any GHG savings. Straw
currently used for animal bedding could also fall into this category.
• Energy crops and short rotation forestry have longer-term potential (post 2020), but will
require strict enforcement of ILUC mitigation measures to ensure the land grown on avoids
food competition as well as being low risk (e.g. protecting carbon stocks).
• A few feedstocks should probably not receive additional support for biofuel production, as
they have multiple competing uses with high risks of detrimental indirect impacts – these
include crude glycerine, grape marcs and wine lees.
• Regardless of the level of competing uses and substitute resources, additional sustainable
feedstock supplies can be found for biofuels production if processes currently used in
competing use sectors improve their efficiency, thereby releasing biomass material whilst
still meeting the same system demands. This effect can apply to almost every feedstock, but
will be particularly important for captive feedstocks such as black & brown liquor, waste
carbon gases, palm oil mill effluent, animal manures and sewage sludge, along with all those
Advanced Biofuel Feedstocks - An Assessment of Sustainability
67
feedstocks with major uses in the heat & power sectors. However, defining the extent to
which different users can improve their efficiency, and are willing to pay the upfront costs of
doing so, is a difficult question to answer. Therefore, the amount of additional low risk
resource that can be generated without indirect sustainability impacts via this approach is
currently unclear, and would require further analysis.
In summary, there is significant potential for biofuel production using low ILUC risk feedstocks. Those
feedstocks that (partially) fail to meet the criteria either do so because agricultural land is being used
(directly or indirectly), or the competing uses are likely to substitute the diverted feedstock with
fossil fuels. However, many of the feedstocks in Annex IX meet the framework criteria – or could do
so where only uncollected fractions are considered, significant productivity improvements are
realised to release material, or when fossil fuel substitution can be avoided.
In terms of a working definition for those Annex IX feedstocks that are lowest risk – many of the
indirect risks can be avoided if under-utilised resources are sustainably sourced, land is not
converted, and competing use sectors are decarbonised. “Under-utilised” encompasses additional
collectable supplies, few competing uses, and/or inefficient consumption that can be improved upon
to release material. Additional policy support is then justified for these low risk feedstocks if RED
minimum requirements regarding land types are met, and biofuel lifecycle GHG emissions are above
a chosen threshold (in light of economy-wide CO2 reduction activities). Different types or levels of
support may also be required to commercialise the biofuel conversion technology and bring down
production costs.
Most of the novel technologies that convert these eligible low risk feedstocks to biofuels still need to
be commercialised, and only a few of the routes are currently economically competitive (compared
to fossil transport fuels or conventional food-based biofuels) – despite the attractive GHG savings on
offer. Ongoing European policy negotiations regarding advanced biofuels need to base the final
Annex IX lists on robust evidence, incorporating clear guidelines and definitions, if the resulting
mechanism is to support truly sustainable biofuels – hopefully, this study is a useful tool to help
move the debate in this direction.
Advanced Biofuel Feedstocks - An Assessment of Sustainability
68
Table 13: Analytical framework results
Feedstock Classification
Risk of food
competition
via ILUC?
Biodiverse, C
stock, peat land?
Competing
uses? Indirect risks? GHG savings
Economic
viability Additional support justified?
Bio-fraction of MSW Waste - - Medium Nat gas (H&P), fertiliser
(compost) Good More costly
Yes, depends on conversion tech
and landfill tax
Bio-fraction of C&I waste Waste - - Medium Nat gas (H&P) Good More costly Yes, depends on conversion tech
and landfill tax
Straw Agric residue - Unlikely a concern Medium-
High Hay (feed) Excellent More costly
Yes, for sust additional potential
or sust bedding alternatives
Animal manure Agric residue - Unlikely a concern Low Low Good Expensive Yes
Sewage sludge Waste - - High Nat gas (H&P) Good More costly Yes for under-utilised fraction
Palm oil mill effluent Waste - - Low Low Biogas unlikely to reach EU
Empty palm fruit bunches Process residue - - Low Low Excellent More costly Yes for under-utilised fraction
Tall oil pitch Process residue - - High Fuel oil (H&P) Excellent Competitive Only if replaced with sust fuel
Crude glycerine Process residue - - High Many (H&P, feed, ind) Good Expensive Likely too many risks
Bagasse Process residue - - Medium Low Good Competitive Yes for under-utilised fraction
Grape marcs Process residue - - High More grape needed Excellent Expensive Industry impact likely too high
Wine lees Process residue - - High More grape needed Good More costly Industry impact likely too high
Nut shells Process residue - - High Coal (H&P) Excellent More costly Only if replaced with sust fuel
Husks Process residue - - High Coal (H&P) Excellent More costly Only if replaced with sust fuel
Cobs Agric residue - Unlikely a concern Medium Hay (feed) Good More costly Yes, where sustainable
additional potential
Bark, branches, leaves Forest residue - Avoid conversion Low Low Excellent More costly Yes, where sustainable
additional potential
Sawdust & cutter shavings Process residue - - High Low if extra sust. wood Excellent More costly Only if replaced with sust fuel
Black & brown liquor Process residue - - High Fuel oil (H&P) Excellent More costly Only if replaced with sust fuel
UCO Process residue - - Medium-
Low Low Excellent Competitive
Yes, where sustainable
additional potential
Animal fats (Cat I and II) Process residue - High Fuel oil (H&P) Excellent Competitive Only if replaced with sust fuel
Miscanthus Product Yes Avoid conversion - - Excellent More costly Only if ILUC mitigation enforced
Short rotation coppice Product Yes Avoid conversion - - Excellent More costly Only if ILUC mitigation enforced
Short rotation forestry Product Yes Avoid conversion - - Excellent More costly Only if ILUC mitigation enforced
Small round-wood Product - Avoid conversion Medium Low if extra sust. wood Good More costly Yes, where sustainable
additional potential
Micro-algae Product Negligible Unlikely a concern - - Threshold Expensive Yes
Macro-algae Product Negligible Not a concern - - Threshold Expensive Yes
Renewable electricity Product Minimal Unlikely a concern - - Excellent Expensive Yes for new sites only
Waste carbon gases Process residue - - Low Nat gas (H&P) Good Competitive Yes for under-utilised fraction
69
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Appendix B - Feedstock definitions
This Appendix contains working definitions for each of the feedstocks considered in the study (or
mentioned in Section 4.1), and highlights the main areas of uncertainty or disagreement. This is
based on IEEP (2013) information, updated and supplemented with insights from the industry and
policymaker interviews we conducted.
European Commission RED & FQD Annex IX feedstocks – multiple counting proposals as of 17
October 2012
Part A. Feedstocks whose contribution towards the target referred to in Article 3(4) shall be
considered to be four times their energy content
(a) Algae.
Micro-algae are generally single-celled whereas macro-algae (seaweeds) are multicellular plant-like organisms.
Algae are found in both marine and fresh-water environments around the world and may be harvested from
wild stocks or cultivated. Given a lack of further definition, the ILUC proposal is assumed to cover algae from
all sources, but not micro-crops such as Lemna spp
(b) Biomass fraction of mixed municipal waste, but not separated household waste subject to recycling
targets under Article 11(2)(a) of Directive 2008/98/EC of the European Parliament and of the Council of 19
November 2008 on waste and repealing certain Directives.
The relevant article of the Waste Framework Directive refers to "paper, metal, plastic and glass’, which leaves
food waste and green waste (i.e. garden waste) as eligible municipal waste streams. It could be construed that
biodegradable plastics and non-separated card and paper are also part of the definition.
(c) Biomass fraction of industrial waste.
This category may encompass a range of waste streams, without further definition provided in the ILUC
proposal. An indicative, non-exhaustive list includes: waste paper, cardboard and wood (e.g. used in packaging
and transport); food waste occurring at the production stage (though some of this, such as animal fats falls
under another biomass category) and also retail stages (supermarkets).
(d) Straw.
Straw refers to the dry stalks of crops that remain following the removal of the grain and chaff during the
harvesting process and can encompass cereal straw (e.g. from wheat, barley, rye, oats), maize stover (but not
cobs), oilseed rape straw, rice straw. This would likely also include sugarcane trash/leaves.
(e) Animal manure and sewage sludge.
Animal manure includes liquid manure and slurry as well as solid manure and dung, produced from cows,
horses, pigs, chickens, sheep and other animals, birds and pets. Solid manures and dungs often contain a high
proportion of straw, given its use in animal bedding.
Sewage sludge is the watery residual and semi-solid material left from industrial wastewater or sewage
treatment processes.
(f) Palm oil mill effluent and empty palm fruit bunches.
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Palm oil mill effluent and empty palm fruit bunches are by-products of the palm oil processing industry.
Typically, for every tonne of fresh palm bunches processed, 0.65 tonnes of palm oil mill effluent will be
produced and around 0.2-0.22 tonnes of empty fruit bunches, the residues remaining after threshing the fresh
fruit bunches.
(g) Tall oil pitch.
Tall oil pitch is a highly viscous residue from the distillation of crude tall oil. Crude tall oil stems from crude
sulphate soap, which is (along with black liquor) a by-product of the conifer based paper pulp making process.
(h) Crude glycerine.
Crude glycerine (also crude glycerol) is a by-product of biodiesel production and the processing of animal and
vegetable fats and oils. It can also be synthesised. Biodiesel production yields around 10 per cent crude
glycerine output. Crude glycerine can be upgraded or refined to yield glycerine, removing methanol and other
impurities, a process that is relatively expensive, at least at a small scale, and there is a lack of refining capacity
in the EU currently.
(i) Bagasse.
Bagasse is the fibrous residue from the sugarcane crushing process, typically around 13% of the wet
unprocessed sugarcane (with the sugar content being around 14%)
(j) Grape marcs and wine lees.
Grape marc, also known as ‘pomace’, is the residue that remains after the pressing of fresh grapes. ‘Wine lees’
refers to the sediment remaining in the vessels used in wine production, consisting of dead yeasts and other
solid particles precipitated during the fermentation process.
(k) Nut shells.
Nut shells are the outer hard casing of nuts. This category is understood to include almonds, though the
proposal does not specify this. The largest source of nutshells in the EU is from almond, walnut and hazelnut
production.
(l) Husks.
Husks (also known as hulls) are the protective outer coating of seeds, nuts, grains or fruit. In the case of wheat,
the husk is separated from the kernel during the threshing procedure. Once removed the husk becomes a
constituent of the ‘chaff’ and is regarded as an agricultural residue. This is thought to primarily refer to the
leafy outer layer surrounding the ear of the maize (corn) plant. A wider definition of husks could include other
plant residues remaining after processing, including olive cores and pulp (which can also be referred to as non-
grape marc and lees).
(m) Cobs
A cob is the central, fibrous core of a maize ear to which kernels or grains are attached. Isolated cobs are a by-
product from the harvesting of grain maize kernels for food, chemicals or biofuels use
(n) Bark, branches, leaves, saw dust and cutter shavings.
This category covers both primary woody residues, such as bark, and branch leaves, as well as processing
residues, such as saw dust and cutter shavings. Primary residues can include forest biomass as well as woody
biomass on non-forest land, such as prunings and cuttings from permanent crops (e.g. olives, vines) and
orchards.
(missing) Black & brown liquors
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Black liquor is the spent cooking liquor from the kraft process when digesting pulpwood into paper pulp
removing lignin, hemicelluloses and other extractives from the wood to free the cellulose fibres. The
equivalent spent cooking liquor in the sulfite process is usually called brown liquor, but the terms red liquor,
thick liquor and sulfite liquor are also used.
Part B. Feedstocks whose contribution towards the target referred to in Article 3(4) shall be
considered to be twice their energy content
(a) Used cooking oil.
Also known as recovered vegetable oil or waste vegetable oil, used cooking oil is typically collected from
catering establishments and industrial food processors as a waste from food production. It may also be
collected from domestic households where a collection infrastructure exists.
(b) Animal fats classified as category I and II in accordance with EC/1774/2002 laying down health rules
concerning animal by-products not intended for human consumption.
Rendered animal fats are obtained by the rendering (crushing and heating) of animal by-products. There are
three distinct categories of tallow products, as defined by the Animal By Products Regulations (ABPR).
Category 3 materials are derived from materials which could otherwise enter the food chain. Category 2
materials are derived from low risk material such as animals that have died on-farm and their manure.
Category 1 material carries a risk which cannot be treated with heat/pressure sterilisation and transformed
into a safe product usable in the feed chain or as fertiliser. It is for example derived from material deemed to
carry a BSE/TSE risk such as spinal and brain material.
(c) Non-food cellulosic material.
Non-food crops grown for the purposes of bioenergy production. These include crops such as Miscanthus,
other energy grasses, certain varieties of sorghum and industrial hemp, but exclude crops with high lignin
content, such as wood products.
(d) Ligno-cellulosic material except saw logs and veneer logs.
This is understood to include dedicated woody energy crops such as Short Rotation Coppice (SRC), e.g. willow
and poplar, Short Rotation Forestry (SRF), as well as small round-wood and pulpwood. There has been no
mention to date by policymakers regarding exclusion of small round-wood or pulp wood from this category,
given their use in the forestry products sector (similar to saw logs and veneer logs).
European Commission RED & FQD Annex IX feedstocks – multiple counting proposals as of 11
September 2013
Part A. Feedstocks from waste and residues whose contribution towards the target referred to in
Article 3(4) shall be considered to be once their energy content and which contribute towards the
2,5% target referred to in Article 3(d)(i)
(b) Biomass fraction of mixed municipal waste, but not separated household waste subject to recycling
targets or separate collection under Article 11(1) and (2)(a) of Directive 2008/98/EC of the European
Parliament and of the Council of 19 November 2008 on waste and repealing certain Directives; derogations
may be granted by Member States for separate biowaste where processes allow the production of both
compost and biofuels.
As defined above, but with additional information on compost.
79
(c) Biodegradable fraction of industrial, retail and wholesale waste, but not waste subject to separate
collection under Article 11(1) of Directive 2008/98/EC, and provided that the waste hierarchy and the
principle of cascading use are respected.
As defined above, but with additional exclusions for better waste hierarchy uses.
(d) Straw.
(e) Animal manure and sewage sludge.
(g) Tall oil pitch.
(h) Crude glycerine.
(i) Bagasse.
(j) Grape marcs and wine lees.
(k) Nut shells.
(l) Husks.
(m) Cobs.
(n) Bark, branches, leaves, saw dust and cutter shavings.
(d)-(n) All as defined above. Note the removal of (f) palm oil mill effluent and empty palm fruit bunches.
(na) Ligno-cellulosic material except saw logs and veneer logs.
This has the same title as Part B (d) the October 2012 proposal – but this is unlikely to have the same definition
as previously (e.g. SRC, SRF), due to the uncertainty surrounding energy crops. It is still unclear whether energy
crops will fall under the 6% food cap, if defined as ‘other energy crops grown on land’ – a RTFG briefing note
mentions that a verbal amendment was made at the last minute to not cap energy crops. It is also unclear
how this feedstock category overlaps with (n) above – as most bark, branches, saw-dust and cutter shavings
are indeed ligno-cellulosic material. We also note that the September 2013 Parliament amendments have the
following definition upfront in the text glossary section: ‘Non-food ligno-cellulosic material’ means land-based
woody energy crops such as short-rotation coppice and short-rotation forestry crops‘ – but that this definition
does not appear to make it into the Annex.
Part B. Feedstocks from waste and residues whose contribution towards the target referred to in
Article 3(4) shall be considered to be twice their energy content
(a) Used cooking oil.
As defined above.
(b) Animal fats classified as category I and II in accordance with EC/1774/2002 laying down health rules
concerning animal by-products not intended for human consumption.
As defined above.
Note the removal of (c) Non-food cellulosic material, e.g. Miscanthus, sorghum, hemp etc. The September
2013 Parliament amendments have the exact same full definition as the Commission, but this definition is
upfront in the text glossary section, not in the Annex. It is also still unclear whether these will fall under the 6%
food cap, if defined as ‘other energy crops grown on land’ – a RTFG briefing note mentions that a verbal
amendment was made at the last minute to not cap energy crops.
Part C. Feedstocks whose contribution towards the target referred to in Article 3(4) shall be
considered to be four times their energy content and which contribute towards the 2,5% target
referred to in Article 3(d)(i)
80
(a) Algae (autotrophic).
As above for Algae. We presume that the word “autotrophic” has been added to exclude dark or aerobic
fermentation methods using algal organisms (e.g. certain sugar to diesel routes). Both micro-algae and macro-
algae as defined previously are autotrophic.
(b) Renewable liquids and gaseous fuels of non-biological origin.
Gaseous or liquid fuels other than biofuels whose energy content comes from renewable energy sources other
than biomass and which are used in transport. This will presumably cover hydrogen from electrolysis using
renewable electricity.
(c) Carbon Capture and Utilisation for transport purposes.
A process that captures carbon (CO/CO2) rich waste and residues gas streams from non-renewable energy
sources and transforms them into fuels that are used in the transport sector. This late addition to the lists will
presumably cover industry off-gas conversion to biofuels, such as syngas fermentation to ethanol (e.g. the
Lanzatech process)
(d) Bacteria.
As discussed in Section 4.1, it is very unclear as to what “Bacteria” is actually meant to encompass, and
whether it is actually a process, not a feedstock. There is no definition available or any further information
regarding potential project developers looking to produce biofuel from this route (and no obvious match in the
public domain) – plus none of our interviewees were able to provide further insight.
81
Appendix C - Feedstock factsheets
The following pages contain the background information gathered for each feedstock. These pages
are stand-alone sources of information (attached separately to this report), arranged by:
• Top bar: Definition, picture
• Upper left: Basic information, properties and supply chain
• Upper right: Feedstock and biofuel supply potential
• Lower left: GHG emissions, competing uses and indirect impacts
• Lower right: Feedstock prices and biofuel production costs
The order of the factsheets follows the Annex IX lists, plus the additional feedstocks identified in
Section 4.1. Note that several of the feedstock classes have been split into two separate factsheets
where this improves transparency, as there are significant variations in properties, volumes,
economics and/or sustainability between the feedstocks within that class.
• Bio-fraction of MSW
• Bio-fraction of C&I Waste
• Straw
• Animal manure and sewage sludge
o Animal manure
o Sewage sludge
• Palm oil mill effluent and empty palm fruit bunches
o Palm oil mill effluent
o Empty palm fruit bunches
• Tall oil pitch
• Crude glycerine
• Bagasse
• Grape marcs and wine lees
o Grape marcs
o Wine lees
• Nut shells
• Husks
• Cobs
• Bark, branches, leaves, saw dust and cutter shavings
o Bark, branches, leaves (i.e. forestry residues)
82
o Saw-dust and cutter shavings
• Black and brown liquor
• Used cooking oil
• Animal fats Categories I & II
• Non-food cellulosic material, e.g. Miscanthus
• Ligno-cellulosic material except saw logs and veneer logs:
o Short Rotation Coppice
o Short rotation forestry/small round-wood
• Algae (autotrophic)
o Micro-algae
o Macro-algae
• Renewable liquids and gaseous fuels of non-biological origin, e.g. renewable electrolysis
• Carbon Capture and Utilisation for transport purposes, e.g. waste carbon gas
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