The Cost of Doing Business

PHOTO: THE WESTERVELT COMPANY

May 9, 2016

BY Ron Kotrba

Last September, Westervelt Renewable Energy LLC, a 300,000-ton-plus wood pellet facility located in Aliceville, Alabama, became the first U.S. pellet producer to achieve certification from the Sustainable Biomass Partnership. SBP certification is a relatively new scheme to demonstrate legal, sustainable biomass sourcing. The organization was created in 2013 to further the work of the former Initiative of Wood Pellet Buyers and its development of a standard biomass trading agreement focusing on pellet specifications, trading terms and sustainability criteria.

“There is currently no agreed definition of sustainability amongst the EU member states,” says Melanie Wedgbury, the SBP communications and information officer. “Some member states, such as Belgium, Denmark, the Netherlands and the U.K. have, or are developing, their own sustainability criteria and regulations.” Wedgbury says an effective mechanism is needed to enable producers and users of woody biomass for energy production to demonstrate compliance with regulatory requirements, including sustainability. The SBP Framework provides such a tool. “There is also a focus on carbon reduction and effectively demonstrating that through carbon accounting,” Wedgbury says. “The SBP Framework also enables the collection and communication of such data.”

Westervelt Renewable Energy began operations in 2013 as SBP was getting its start. The Alabama pellet mill, which uses roundwood thinnings and residual chips as feedstock, is owned by The Westervelt Company, a land resource organization founded in 1884 committed to sustainable forestry practices, says Alicia Cramer, president of Westervelt Renewable Energy and parent company vice president of business development. The mill stores finished pellets in on-site silos and its location on the Tombigbee River provides direct access for barge shipment to the Port of Mobile and destination markets in Europe. The parent organization operates in multiple arenas and industries including timber and natural resources, Southern Yellow Pine lumber, ecological services and renewable energy. Westervelt sought SBP certification, according to Cramer, because of its customers’ mandate to demonstrate to regulators the legality and sustainability of feedstock at all points in the supply chain, from forest to combustion. “SBP is a defined pathway to achieving this objective,” Cramer says. “SBP certification ensures a level playing field across the producer market and allows for greater product fungibility,” meaning product interchangeability regardless of the country in which it’s used.

Program Protocol
SBP fully recognizes the credibility of existing, proven forest certification programs such as the Forest Stewardship Council, the Programme for Endorsement of Forest Certification, the Sustainable Forest Initiative and the American Tree Farm System, and Wedgbury says SBP does not intend to compete with or replicate them. “There is, however, limited uptake of certification in some key forest source areas or wood baskets,” she says, “and the schemes themselves do not yet cover all the key regulatory requirements faced by users of woody biomass for energy production. Therefore, SBP has developed standards and a certification system, the SBP Framework, to overcome these challenges and address the gaps.”

Six standards make up the SBP requirements. For the biomass to be SBP-compliant, all standards must be met and processes followed, Wedgbury says. The six standards are 1) Feedstock Compliance Standard; 2) Verification of SBP-compliant Feedstock; 3) Certification Systems/Requirements for Certification Bodies; 4) Chain of Custody; 5) Collection and Communication of Data; and 6) Energy and Carbon Balance Calculation. Wedgbury says biomass producers are assessed against Standards 1, 2, 4 and 5, and biomass traders are assessed against Standards 4 and 5.

“Under the SBP Framework, the biomass producer is the first point of certification,” Wedgbury says. An example of a biomass producer would be a pellet mill such as Westervelt Renewable Energy. “They are assessed for compliance with the SBP requirements, specifically that the feedstock it uses is compliant with SBP requirements—essentially that it is sourced both legally and sustainably,” Wedgbury says. The assessment must be carried out by an independent third-party certification body. FSC- or PEFC-certified feedstock, including feedstock with a certification claim from FSC- or PEFC-approved schemes, is automatically SBP-compliant. All other feedstock must be evaluated. Standard 1 is what the feedstock is evaluated against and Standard 2 defines how the evaluation of feedstock should be conducted. Producers demonstrating compliance receive a certificate and can make the claim that the biomass it produces is SBP-compliant.

The feedstock supply base evaluation is a risk-based approach. The biomass producer must carry out a risk assessment to identify the risk of compliance with each indicator detailed in Standard 1. Each indicator is scored as either a low or specified risk. For specified risks, the producer is required to install measures to mitigate risks to deem them low. The mitigation measures must also be monitored. During risk assessment, the producer must consult with stakeholders and provide a public summary for transparency.

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Biomass users (e.g., power plants) have to show legal and sustainability credentials of the material to comply with regulatory requirements. Wedgbury says under the SBP Framework, biomass users will be able to provide evidence that the biomass is sustainable by linking back to the feedstock harvested and including information related to each step of the supply chain, from origin through trade, transport and processing.

Wedgbury says once the producer demonstrates feedstock origin, then they and each element in the supply chain—including trade, transport and processing—requires chain-of-custody certification by independent third-party certification bodies, if those organizations or their customers take legal ownership of the product and wish to make SBP claims about their product. Standard 4 details the systems required and establishes limits to how feedstock and biomass may be mixed.

“In order to meet the growing need for various greenhouse gas and profiling data demanded by the regulatory requirements of certain EU member states, SBP defines the requirements and options for collecting data that must accompany SBP-compliant biomass,” she says. “Again, as with the chain of custody information, all parties that take legal ownership of the biomass and wish to sell the biomass as SBP-compliant with certified greenhouse gas and profiling data must obtain certification by an independent third-party certification body.” Standard 5 specifies how required data are to be collected and transmitted along the supply chain. Standard 6 allows for the certification of the energy and carbon balance calculation. Wedgbury adds that certification bodies provide third-party independent assurance that the SBP Framework is adhered to, providing confidence in the legal and sustainable sourcing of woody biomass.

Westervelt’s Perspective
Currently 16 biomass producers, three of which are located in the U.S., and two biomass traders hold SBP certification, Wedgbury says. With Westervelt being the first U.S. pellet producer, and among the first globally, to achieve SBP certification in this relatively new, evolving scheme—one that was certainly in development as Westervelt sought certification—the process was not as streamlined or efficient as it is now. “A pellet producer starting down the path today will find this to be a smoother and relatively quicker journey than it was for us,” says Mike Williams, project director for The Westervelt Company. “For our company, this was a multiyear process that began with a small group of U.S. Industrial Pellet Association producer and landowner members, along with producers from other countries, meeting with SBP’s Assurance Framework Development Group as they developed the initial draft standard. What followed was a series of workshops that allowed for a detailed information exchange, which ultimately led to the standard we have today. This was very important because we were able to accurately portray the reality of the U.S. forest sector and dispel the myth that it is unregulated and without oversight of any type.”

The formal certification process began in late 2014 with a readiness review conducted by a certification body to ensure Westervelt was prepared to proceed with a formal audit. “This was particularly important because the standard was new to Westervelt, the certification body, and to SBP,” Williams says, adding that SBP’s technical director participated in the audit along with a third-party consultant engaged by the certification body to monitor their work. “Our certification body, NSF International, was selected because of its extensive knowledge of our company’s forest and sustainability practices, of forest sustainability and certification systems in general, and its commitment to take on this new standard,”  Williams says. “Although NSF is very familiar with our company, it approached this as if no prior audits had been conducted and required that everything be verified—it was not simply a matter of pointing to an existing certification to avoid harvest site visits or other key audit requirements. It was very thorough.” He adds that the comprehensive approach met Westervelt’s desire to deliver a robust, objective and defensible audit process.

Gaps identified during the readiness review were resolved and the base audit was conducted in late February 2015, followed by the greenhouse gas verification in April 2015. Once approved by the certification body, it was submitted to SBP for technical review and certification was complete by September 2015.

Williams says because Westervelt is first and foremost a land owner—pellets is not its primary business—the company’s sustainability practices were already well-established. “They form the underlying foundation and evidence required to satisfy a majority of SBP Framework requirements,” he says. “This is one reason we were comfortable taking an early step toward certification.” Having been audited to several forestry and chain of custody certifications over more than a 10-year period, Williams says Westervelt was confident at the outset that its practices were comprehensive and robust. “We were pleased to have this validated through the SBP audit process,” he says. However, because of specific European country reporting requirements, it was necessary in some cases to be more granular in its collection and reporting of data, Williams says. “Fortunately, these were relatively minor changes to our systems,” he explains. “We also reinforced the focus on areas where the potential for land use change exists and in areas of high conservation value when conducting logger training.”

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Prior to SBP certification, Westervelt’s company-owned forests were already certified to both SFI and FSC standards, and it holds PEFC, SFI and FSC chain-of-custody certifications. In addition to SBP Framework certification, Westervelt is also certified to the Green Gold Label chain-of-custody and processing standard.

Because SBP builds on existing sustainability practices, many of the resources needed were already in place at Westervelt, so Williams says it was unnecessary to hire additional, dedicated personnel for the new certification process. For a couple of reasons, however, the company did hire a third-party consultant for development of the supply-base evaluation and risk assessment. “First, the task was very time-consuming and detailed,” he says, “and second, we felt a third-party assessment would add credibility.” Williams notes that it’s also important to keep in mind that standards revisions and maintenance of greenhouse gas data is an ongoing activity that must be managed.

Costs to gain SBP certification will vary depending on a producer’s existing certifications and practices. “In our situation, we are able to integrate the SBP certification audit into our regular audit cycle, which increases the amount of man-days required but does not result in a separate audit,” Williams says. “Essentially, the certification body is qualified to audit to multiple standards when reviewing records, visiting harvest sites and so forth. SBP is not free, but it will hopefully become an incremental cost for us.”

Full certification audits occur every five years and are more costly than the surveillance audits that occur during interim years, Williams says. In addition, SBP recently announced a schedule implementing new fees related to report review and applications, which certifying bodies will most likely seek to recover from producers. The new fees, effective this October, also impact pellet producers directly via a per-ton fee of €0.15 (17 cents) for all biomass supplied with an SBP claim. Come April 2017, biomass producers supplying wood chips with an SBP claim will be assessed a per-ton fee of €0.08. Nonproducers holding a chain of custody certificate from SBP, such as traders, pay an annual fixed fee of up to €25,000 a year. Micro entities supplying less than 100,000 tons pay nothing, and entities supplying between 100,000 and 249,999 tons are assessed an annual fixed fee of €10,000.    

The most challenging aspect of the overall process for Westervelt, according to Williams, was prior to approval of the standard itself and dates back to the producer meetings with AFDG. “Many European regulators are only familiar with FSC and do not have an in-depth understanding of SFI and ATFS certifications,” he says. “The concept of multiple small forest landowners and their ability or willingness to pursue certification continues to be an issue. We hope to make further progress on this as the standard evolves.”

While Westervelt encountered no major barriers to success in SBP certification, Williams says from his perspective it’s always beneficial to objectively review findings to determine what can be learned, and how processes can be further improved. Wedgbury says SBP accepts all constructive criticism and the program is developing “at an extraordinarily fast pace”—faster than any other scheme on the market.

Ultimately, Williams says the company hopes to achieve three key outcomes from SBP certification: Elimination of multiple utility audits, acceptance of common standards by European regulators, and increased product fungibility. “In this business, proving sustainability is part of the cost of doing business and is not something that is going to lead to a premium price,” he says.

Author: Ron Kotrba
Senior Editor, Pellet Mill Magazine
218-745-8347
rkotrba@bbiinternational.com

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