Sustainability: the key to future incentive schemes

RED2 DEFINES THE NEW CRITERIA TO BE RESPECTED FOR THE BIOENERGY SUSTAINABILITY

With the recent publication of Legislative Decree No. 199 8 November 2021, the EU Directive 2018/2001 promoting the use of energy from renewable sources has been adopted; it introduces a number of important innovations regarding the sustainability of bioenergy that affect the production of biogas/biomethane.

First of all, let us recall what are the requirements (introduced by the RED I and confirmed by the 2018/2001 Directive) for a bioenergy to be considered “sustainable”:

1) the fields from which are harvested the crops and crop residues used for bioenergy, have not to be high value land because at high carbon stock (forests, peatlands, etc.) according to Art. 29 of the RED Directive;

2) the quantity of equivalent CO₂ emitted for bioenergy production, have to be lower of a pre-established percentage depending on destination (transport, electricity, heating/cooling), compared to the “fossil fuel comparator” or “fossil fuel comparator (FFC)” emissions.

Regarding this last point, the table well highlights the main changes introduced with the adoption of Directive 2018/2001. Firstly, compliance with sustainability requirements, initially required only for biomethane as a “biofuel”, has been extended also to biogas/biomethane used for power generation and heat production.

In addition to updating the emission values associated with the Fossil Fuel Comparator, other important changes are the CO₂ eq. emissions associated with livestock manure (finally taking into account the “avoided emissions” from their storage) and the inclusion of the CO₂ eq. emission values associated with maize chopped.

Compliance with and demonstration of the “sustainability” of renewable energy sources generated from biomass are necessary and mandatory requirements in order for them to be counted towards the European renewable energy targets. It follows that biogas plants, in order to be the recipients of economic incentives, must in turn demonstrate that the bioenergy they produce is “sustainable” and to do this they must adhere to the National Certification System of the sustainability of biofuels and bioliquids, established by the Decree of 14 November 2019, which, in turn, must be updated, as specified in the same Legislative Decree 199/2021.

We recall that, at national level, the issue of biomethane sustainability and the relative need to “certify” this sustainability was introduced by the Decree of 2 March 2018, which promotes and incentivises biomethane as a biofuel for transport and identifies and distinguishes two types, “advanced” biomethane and non-advanced biomethane. Both types, however, are first of all sustainable under the Decree of 14 November 2019 and according to the criteria set out in the current RED.

Operatively, the demonstration of biomethane sustainability according that criteria must be certified by an external party, specifically by a certification organization (CO) licensed by Accredia. That is in accordance with the Decree of 14 November 2019, where is defined the National Certification System for the sustainability of biofuels and bioliquids.

Thereby, the farm that want to produce biomethane for transport or other uses, have to know this new and complex scenario. Starting from the diet definition during the phase of plant authorisation, to the preparation of the documents required by CO, the farm has to manage all those passages in order to obtain the “Certificate of Sustainability”, that is needed for access to incentives.

The CIB, aware of this complexity, immediately moved in two directions: first of all, from the beginning it gave a support to the first members who were ready to start with biomethane for transport. Then it identified the CSQA as the certification organization with which interact in order to give a detailed address for the correct application of the sector’s standards.

This double approach has allowed to address a number of critical interpretation issues and to identify shared solutions that were immediately applied.

Considering the opportunities provided by the application of RRNP, the demonstration of the sustainability will be a necessary condition for access to the new incentives for both existing and new biogas plants. Those conditions are expected to be introduced by the new decrees that will guarantee the continuity of our sector and that are in definition in those weeks.

The verification of the sustainability criteria is a fundamental activity that it must be addressed, starting with the type and quantity of the biomasses that will feed the digester, from the preliminary planning of a new plant or from the planning of the conversion of an existing one. In fact, based on feeding choiches and the characteristics of future plant, it is possible to understand if it will be able to produce sustainable biomethane and receive the incentives.

In order to be ready to take part in the calls for tenders planned for 2022, that will implement the funding measures provided for in the RRPN (capital grants of up to 40% of the investment cost), it is necessary to have already carried out all the relevant assessments in terms of compliance with sustainability criteria. Aware of the relevance of this phase for the correct start of all initiatives, CIB Service, thanks to his experience, has set up a dedicated sustainability consultancy service by CIB Service to enable producers to be ready to gain all the development opportunities offered by the RRPN.