European renewable energy directive: Critical analysis of important default values and methods for calculating greenhouse gas (GHG) emissions of palm oil biodiesel

The aim of this paper is to evaluate assumptions and data used in calculations  related to palm oil produced for biodiesel production relative to the European Renewable Energy Directive (EU-RED). The intent of this paper is not to review all assumptions and data, but rather to evaluate whether the methodology is applied in a consistent way and whether current default values address relevant management practices of palm oil production systems.

The GHG calculation method provided in Annex V of the EU-RED was used to calculate the GHG-emissions from palm oil production systems. Moreover, the internal nitrogen recycling on the plantation was calculated based on monitoring data in North Sumatra.

A calculation methodology is detailed in Annex V of the EU-RED. Some important aspects necessary to calculate the GHG emission savings correctly are insufficiently considered, e.g.:

• “Nitrogen recycling” within the plantation due to fronds remaining on the plantation is ignored. The associated organic N-input to the plantation and the resulting nitrous oxide emissions is not considered within the calculations, despite crop residues being taken into account for annual crops in the BIOGRACE tool.

• The calculation of GHG-emissions from residue and waste water treatment is inappropriately implemented despite being a hot-spot for GHG emissions within the life cycle of palm oil and palm oil biodiesel. Additionally, no distinction is made between palm oil and palm kernel oil even though palm kernel oil is rarely used for biodiesel production.

• The allocation procedure does not address the most relevant oil mill management practices. Palm oil mills produce crude palm oil (CPO) in addition either nuts or palm kernels and nut shells. In the first case, the nuts would be treated as co-products and upstream emissions would be allocated based on the energy content; in the second case the kernels would be treated as co-products while the shelöls are considered as waste without upstream emissions. This has a significant impact on the resulst or GHG savings, respectively.

• It is not specified whether indirect GHG emissions from nitrogen oxide emission from the heat and power unit of palm oil mills should be taken into account.

In conclusion, the existing calculation methodology described in Annex V of the EU-RED and default values are insufficient for calculating the real GHG emission savings from palm oil and palm oil biodiesel. The current default values do not reflect relevant management practices. Additionally, they protect poor management practices, such as the disposal of empty fruit bunches (EFB), and lead to an overestimation of GHG savings from palm oil biodiesel. A default value for EFB disposal must be introduced because resulting GHG emissions are substantial. Organic nitrogen from fronds must be taken into account when calculating real GHG savings from palm oil biodiesel. Further, more conservative data for FFB yield and fugitive emissions from wastewater treatment should be introduced in order to foster environmental friendly management options. Moreover, credits for bioenergy production from crop residues should be allowed in order to foster the mobilization of currently unused biomass.