1. RTFO Unit, Low Carbon Fuels, UK Department for Transport
Governmental use of sustainability standards: examples & lessons from the UK RTFO
ISEAL conference, Zurich, 8 June 2011
Dr Keeley Bignal - Sustainability Technical Guidance Specialist
RTFO Unit, Low Carbon Fuels, UK Department for Transport

2. Overview UK biofuel policy C&S reporting
RTFO Biofuel Sustainability Meta-standard
Benchmarks of sustainability schemes against the Meta-standard
Benchmarks against the RED carbon stock and biodiversity criteria
Uptake of standards by suppliers of biofuel to the UK
Lessons learnt

3. UK biofuels policy: the Road Transport Fuel Obligation
Introduced in 2008
Duty point obligation
2.5% biofuel volume rising to 5% 2013
Tradable certificates & buy-out option (30ppl)
Carbon & sustainability reporting

4. Carbon & sustainability reporting scope

5. Carbon & sustainability reporting overview
To claim RTFCs C&S reports must be supplied
C&S data must be independently verified
Annual targets for company performance (no penalty for failing to achieve)
Company targets
Percentage of feedstock meeting the ‘Qualifying’ Environmental Standard
30%
50%
80%
GHG saving
40%
45%
Data provision
70%
90%

6. C&S reporting - the 'RED-ready' approach
RTFO C&S reporting adapted to be as consistent as possible with the EC requirements from the start of the third year of the RTFO on 15 April 2010
Aim to help UK industry best prepare for the RED
Aim to be transparent about which batches of fuel are indicatively RED-ready
RTFO continues to require C&S reporting rather than mandatory minimum performance until RED implementation

7. Benchmarks of sustainability assurance schemes against the RTFO Meta-Standard
Environmental
Principle
Bonsucro
RSPO
RTRS
Red Tractor
RSB
SA8000
Pro-terra
Conservation of carbon
Conservation of biodiversity
Soil conservation
Sustainable water use
Air quality
Social
Workers rights
Land rights
Meta-std – multi-stakeholders involved in development, WG etc to get stakeholder buy in, ensure robustness of criteria
Set of 5 env and 2 social principles with sub criteria and a number of recommendations
It is not a certification scheme and is not managed– it’s a set of principles with audit quality rules
As well as providing a set of sustainability principles to assess existing schemes against it’s also possible for suppliers to perform their own benchmarks against the principles
2 suppliers are doing this
Always intended to be an interim solution until sustainability schemes operational for all feedstocks and in all regions
BUT – no standards meet the full meta-standard.
Therefore the concept of the qualifying standards was developed to try and drive uptake of the schemes and drive sustainability forward.

8. The norm for Qualifying Standards
Qualifying Environmental Standard:
Full compliance with all criteria referring to compliance with national legislation (2.1, 3.1, 4.1, 5.1);
On all principles one ‘partial compliance’ criterion is permitted per principle, with a maximum of three in total.
Qualifying Social Standard:
On principle 6, seven of the 11 criteria must be fully complied with;
On principle 7 on land right issues and community relations, one partial compliance is permitted.

9. The norm for audit quality
Any scheme needs to be properly verified/audited to provide assurance that the sustainability criteria have been met

10. Benchmarks of sustainability schemes against the RTFO Meta-Standard
Environmental
Principle
Bon sucro
RSPO
RTRS
Red Tractor
RSB
SA8000
Pro-terra
Conservation of carbon
Conservation of biodiversity
Soil conservation
Sustainable water use
Air quality
Social
Workers rights QS
Land rights
Qualifying standards
Not qualifying standards
The Social Accountability 8000 standard provides a good coverage of worker rights and working relationship concerns, but does not cover land rights or community relations sufficiently well for it to meet the Social Qualifying Standard level.
The ProTerra criteria and indicators alone suggest that the standard could meet the Qualifying Standard level. However, most of the criteria included in ProTerra are not mandatory for certification with no set deadline for meeting them. Therefore, ProTerra certification currently does not guarantee that these important criteria are complied with. Furthermore, the ProTerra standard does not offer an independent accreditation process, and as such does not guarantee the audit quality. It is therefore not currently a Qualifying Standard.
Other standards were benchmarked but didn’t meet the criteria. These were put forward by stakeholders but whilst they were good standards for food quality, safety, traceability etc they weren’t designed to be sus schemes.
Not qualifying standards
Qualifying standards

11. Indicative RED Benchmark
Red
Tractor
FSC
Genesis
LEAF
RSB
+RED
RSPO
RTRS
(draft)
SAN/ RA
Ref date (biodiversity)
Primary forest
Nature protection
Ecosystem protection
Natural grassland
Species rich non-natural grassland
Ref date (carbon)
Wetlands
Continuous forest
10-30% canopy forest
Ref date (peatland)
Peatland
As part of the RFA’s move to prepare stakeholders for RED we assessed schemes against the RED biodiversity and carbon-stock criteria.
Some of these benchmarks were performed before April 10.
No schemes had GHG criteria at the time these were benchmarked
Some schemes have since developed or are in the process of developing RED add on/modules.
We have not rebenchmarked these and are awaiting the Commissions’ assessments.
We did not want to benchmark them whilst the P&C were in a state of flux
Have since done Bonsucro with RED criteria (met C stock and biodiv)

12. Key gaps & challenges
No operational sustainability schemes currently assess GHG savings – though some are in development
At time of RFA assessment only two schemes were strong enough on LUC to meet RED criteria on preservation of carbon stocks – some have now developed EU ‘add-on’ modules to cover this
Many key biofuel feedstocks are not covered by an operational sustainability scheme
Few cover the chain of custody – some are in development

13. Monthly reporting format – using sustainability standards to identify RED-readiness

14. Moving sustainability forward
RFA contacted standards bodies with recommendations - ‘simple’ updates in many cases to align with RED:
inclusion of reference date for LUC
aligning reference date with Jan 2008
more explicit and specific on carbon conservation requirements
Several schemes are progressing quickly to cover key feedstocks – e.g. RTRS, BSI, ISCC, RSB
Several schemes are developing EU market access/ RED add-ons in response to market demand/regulatory framework
RTFO Meta-Standard can be used in absence of operational assurance schemes

15. Biofuels supplied under the RTFO† - performance against the targets
Annual supplier target
Year 3
Year 2
Year 1
Target
Actual
% of road transport fuel
3.5%
3.29%
3.25%
3.33%
2.5%
2.7%
% of feedstock meeting a Qualifying Environmental Standard
80%
49%
50%
31%
30%
20%
Annual GHG saving
55%
45%
51%
40%
46%
Data capture
90%
82%
70%
72%
64%
Some improvements in uptake of standards over time though still a long way from the yearly targets
Year One = 15 April 2008 – 14 April 2009
Year Two = 15 April 2009 – 14 April 2010
Year Three = 15 April April 2011 15

16. Environmental sustainability
Year One
Year Three
Year Two

17. Environmental sustainability by company
Company performance – Year One
Clearly a difference in performance between companies

18. Environmental sustainability by company
Company performance – Year Two
Clearly a difference in performance between companies

19. Environmental sustainability by company
Company performance – Year Three
Clearly a difference in performance between companies

20. Key RED sustainability features
RTFO data – are we ready for RED?
First 9 months of Yr 3
71% of biofuel met the 35% GHG saving threshold (may not have met all sustainability criteria e.g. unknown land use)
13% from unknown land use
49% met an environmental standard
35% GHG savings
Cross-compliance
High carbon stock protection*
Wetlands
Peatlands
Continuous forest
High biodiversity protection*
Undisturbed primary forest
Conservation areas
Biodiverse grassland
*Post Jan 2008 20

21. Lessons learnt
The standard must be fit for purpose e.g. a scheme may be designed for food safety but not for environmental sustainability
Engage the standard owner
Inform them of process and purpose of benchmarking
Ensure you have the latest (and all) documentation
Inform them of the results before finalising
Can work with the standard owners to drive sustainability
Consult with experts and stakeholders on benchmark results
Be realistic – set the ‘standard’ you are aiming for but recognise that there may be interim steps to get there
Get ‘buy-in’ from stakeholders – need the fuel suppliers and supply chain to provide the demand for sustainability schemes

22. Lessons learnt Voluntary C&S reporting works
Uptake of sustainability schemes has increased over time
Providing public access to data has driven individual companies to improve performance
Voluntary reporting can provide a ‘stepping stone’ to mandatory sustainability