Please see below for comments by Salva la Selva and Biofuelwatch –
Click here to read the report to which the EIB has responded below.
Email received from the EIB email, 11th September 2020
The European Investment Bank (EIB) would like to thank you for sharing the report on the Curtis Biomass Plant, which presents the authors’ understanding and opinions about the legal framework and good practices for a project such as the one at issue.
The EIB would like to clarify that all EIB-financed projects undergo a due diligence process that is aligned with European Union (EU) policy objectives and regulatory framework, including their transposition through national legislation. This has been the case for the Curtis Biomass Plant.
In applying its due diligence standards for biomass harvesting and supply to bio-based industries (including biomass to energy), the EIB requires the application of sustainable forest management practices.
All forest management within the EU must apply sustainable forest management principles (i.e. EU Forest Strategy, Forest Europe process), typically through forest management plans or equivalent, including integration of protection/biodiversity conservation aspects, as well as measures for preventing/mitigating natural hazards such as e.g. wildfires. Sustainable forest management plans or equivalent are prerequisites for international forest certification (e.g. FSC/PEFC) and the national and regional forest law.
In Mediterranean context, active sustainable forest management represents an efficient means of preventing/mitigating forest/wild fires. Harvesting residues left on site as well as dense and young unmanaged/poor managed forests may constitute substantial fuel loads that exacerbate the risk of forest/wild fires, under the changing climate conditions. Removing the fuel load from these forests for bioenergy generation is a means of preventing fire ignition and/or reducing the scale of wildfires (when they occur).
As part of the EIB monitoring, and with regard to efficiency and emissions, the Promoter has informed the EIB that the net electrical efficiency of the Plant is in excess of 32% and the particulates’ weekly average level is below the reference value of 10mg/Nm3.
With regard to the use of logs, the Plant has four biomass crushers designed to manage mainly bundles, but also logs. In this respect, the Promoter has informed the EIB that during the test period the equipment was also tested with logs to ensure it met the technical specifications.
More information about the EIB’s assessment of the environmental implications of Plant can found in the project summary and in the EIB Group Complaints Mechanism’s (EIB-CM) Initial Assessment Report in case SG/E/2019/04. As the case is currently ongoing, a final position on the allegations has not yet been reached.
Finally, the EIB recalls that the European Commission and Member State judicial authorities are competent to assess allegations about violations of EU law and national implementing legislation, for example in relation to permits.
We hope that you find this feedback useful and remain available in case you need clarifications.
EIB Civil Society Division
Comments by Salva la Selva and Biofuelwatch:
All of the weblinks/documents shared by EIB in their response were analysed by the authors and the information contained in them is reflected in the report. One of the weblinks shared includes the technical details about the plant’s low net efficiency (27.49%) and the very high permitted air emissions discussed in the report. The EIB now states that “the Promoter has informed the EIB that the net electrical efficiency of the Plant is in excess of 32% and the particulates’ weekly average level is below the reference value of 10mg/Nm3“. However, no evidence for this claim has been shared, and neither figure is contained in any of the EIB’s published documentation about the project.
The EIB further states that, according to Greenalia, logs were used during equipment testing, but does not deny them having been used during routine opertions. The report authors note that photographic evidence of roundwood use can be found on the website of two of the technology suppliers for the plant, in addition to that obtained during.
The report authors are particularly concerned about the EIB’s statement that “European Commission and Member State judicial authorities are competent to assess allegations about violations of EU law and national implementing legislation, for example in relation to permits”. It is the EIB’s own responsibility to ensure that it does not grant any loans to projects unless those comply with all EU legislation.