Biogas in Transport Distribution Obligation
After legislative changes, biogas was included in the transport distribution obligation starting at the beginning of 2022. As a result, the bio-share of fuels distributed for transport can now be fulfilled with biogas. However, the condition is that the biogas must be produced sustainably.
The definitions and requirements for sustainability come from the EU's Renewable Energy Directive, commonly known as the REDII Directive. In practice, an operator distributing biogas for transport use must meet the directive's sustainability criteria and report them annually to the Energy Authority. By doing so, the produced biogas and biomethane can be counted as renewable energy, enabling the operator to join the voluntary distribution obligation. In summary, the sustainability criteria mean that the raw materials used to produce biogas must be sustainable—they should not detract from food production, nor should their use increase the need for agricultural land. Additionally, the greenhouse gas emissions from biogas production must be significantly lower than those of fossil alternatives.
15 Years of Biogas Expert Services
Our company, Envitecpolis, just celebrated its 15th anniversary. Over the years, biogas-related expert services have become our mainstay. We have been privileged to be involved in numerous biogas investment processes and actively develop our industry. In recent years, we have had a front-row seat to observe the evolving needs related to sustainability and the accompanying discussions. Through customer needs, we have sought to help first in the form of sustainability assessments and later by building sustainability systems.
A significant aspect of our customers' needs has been the strong use of agricultural biomass as feedstock for biogas plants. Plants based on waste and residues are straightforward because the feedstocks are essentially zero-emission. In contrast, feedstocks from agriculture are special and require the evaluator to understand the agricultural operating environment. Manure from livestock farms is a good example of this. A biogas plant improves manure management and reduces emissions from manure. The reward for this is emission credits in the sustainability assessment. Other agricultural biomasses include expired and spoiled batches of fodder, straw, buffer zone and green manure leys, and surplus leys harvested for the plant. But when is it considered agricultural waste and residue by regulations, and when is it agricultural biomass? This has been a key issue we have worked on with our customers and the Energy Authority.
Collaboration with the Energy Authority
We are pleased to note that the Energy Authority has been an excellent partner in clarifying these issues. Many things have been anything but clear on both sides of the table, but still, a clear answer has been found for every question sooner or later. The authority has aimed to make enabling decisions for biogas production whenever possible within the regulatory framework. Hats off to them.
A Milestone in Grass Biomass
The finest example of this came in the summer of 2023, when the Energy Authority interpreted that grass biomass meeting sustainability criteria can be considered sustainable. This decision means that gas produced from grass can also fulfill the distribution obligation without restrictions, and its tax treatment is equivalent to that of sustainable biogas produced from waste and residues. This interpretation was not a given, and thanks for the groundwork go not only to the Energy Authority but also to the active efforts of SBB and Farmers Union MTK.
Meeting Biogas Sustainability Criteria
However, it is essential to underline that biogas is not automatically sustainable. Sustainability criteria must be met in every situation. The most crucial of these is the emission reduction criterion, which is practically demonstrated through greenhouse gas accounting. The climate emissions from biogas production are compared to those of fossil fuels with equivalent energy content. For example, the emission reduction requirement for new biogas plants is at least 65%. Such a reduction is not achieved with, for instance, grass feedstock cultivated on peat soils. Additionally, many other details influence the overall picture, such as yield level, logistics, machinery chains, plant operation and sizing, methane leaks, and more. The entire chain must be managed and included in the assessment.
The Permanence of Sustainability Needs
Together with industry players, we have concluded that the need to demonstrate biogas sustainability is here to stay; it is a new integral part of a successful biogas plant investment process. A well-conducted sustainability assessment during the planning phase of the plant ensures that there are no unpleasant surprises and that things do not go awry once the plant is operational.
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