The simplest method for demonstrating compliance is to prove that raw materials were sourced from a certified forest. In the US South, however, this is problematic. The Southern Group of State Foresters reported in 2011 that just 38 million of the South’s 214 million forested acres are certified by FSC, SFI, or ATFS. Because the vast majority of timberland owners have small timber tracts—less than 50 acres—and because they make harvest decisions based on sawtimber markets in which no price premium for certified wood is offered, few will be inclined to submit to the certification process. In most cases, therefore, alternative documentation will be needed.
While a final description of the evidence that will be acceptable for proving that the forest source of a pellet mill’s biomass feedstock has been managed sustainably, DECC has announced that these standards will be based on, though not exactly the same as, those developed by the Central Point of Expertise on Timber (CPET). Currently, these standards only apply to the procurement of wood products by the UK government. They will expand to cover biomass before the beginning of second quarter 2014.
What Evidence of Biomass Sustainability Will Be Acceptable?
CPET currently accepts three types of alternative evidence, also known as Category B evidence. Proof of sustainability can be demonstrated through first, second or third party verification.
First Party Verification
- Definition: Occurs when the forest owner re-checks and confirms compliance.
- Form: The landowner submits a supplier declaration, which provides information confirming compliance.
- Includes: The definition of sustainability used by the organization or landowner, details about how these requirements are being met, the date and signature of the landowner or senior manager, and any relevant background information, such as policy commitments.
- Not sufficient: Anything that does not provide specific information about the supply chain and control mechanisms in place, including a signed letter stating that the wood came from legal or sustainable source, confirmation of membership in and organization or subscription to a voluntary code of practice, or ISO 9000 or ISO 14001 certificates (unless they include explicit and demonstrable evidence that the source is managed sustainably). A supplier declaration may contain any or all of these, but no single one of them can comprise the whole of the declaration.
- Appropriate for: Because it is not in the interest of these suppliers to admit to forest sustainability and management issues, this level of verification is only acceptable for low risk situations. Wood sourced in countries with consistent forestry legislation, clear legal use rights for forests, evidence that laws are enforced and where corruption is not an issue is generally considered low risk.
Second Party Verification
- Definition: Checks carried out by the purchaser of biomass, in this case either the broker or the pellet facility.
- Who: The credibility of verifier or auditor is key. The further this person is removed from the forest landowner, the better, making the pellet mill a better source of verification than the broker. This person is generally either a professional auditor or an employee who has the expertise and technical ability for performing the work but without prior knowledge of the issues being verified.
- Methodology: Ranges from a formal audit to an informal conversation. This can entail a look at the entire way the forest is managed, verification of information in a supplier declaration or a follow up on particular issues or problems.
- Includes: Information on how the verification was performed and by whom, including the way information was collected and confirmed.
- Appropriate for: Medium risk situations. Because pellet manufacturing personnel have a stake in the ability of their organizations to make sure their buyers meet the sustainability requirements, this is a step up from first party verification.
Third Party Verification
- Definition: A first or second party contracts with an independent, neutral third party to conduct a formal verification.
- Who: The auditing organization must conform to ISO Guide 65 and, when the government is not satisfied with the evidence provided, it requires verification from an organization that conforms to ISO Guide 65 and ISO 17011 or equivalent.
- Methodology: Undertaken annually, the audit might look at the entire way the forest is managed, verify information in a supplier declaration, or a follow up on particular issues or problems.
- Includes: Who performed the verification, whether individuals or an organization; the frequency and date of verification; the requirements checked; and the methodology used.
- Required for: 1) High risk situations (i.e., countries with conflicting forest sector laws, high incidence of illegal practices, political instability and corruption); 2) verification of sustainability.
It will be important for wood pellet manufacturers to assist their buyers by taking an active role in sustainability verification. The ramifications of not doing so are clear. At a recent meeting of the US Industrial Wood Pellet Association (USIPA), a representative for one utility had this to say: “We are going to see a great deal of data being required of suppliers. We have canceled contracts because adequate data was not available.”