Appendix to Responsible Sourcing - Drax

Appendix to Responsible Sourcing

We will only use

Responsibly sourced sawmill residues

  • Sawmill residues that are compliant with both local and UK law; do not cause deforestation, degradation or displacement of solid wood products; compliant with UK GHG regulations. This is subject to independent 3rd party audit.

Forest residues from regions with high rates of decay, or where this material is extracted to roadside as part of standard harvesting practice

  • In many regions, it is common practice to extract tops and branches to roadside during harvesting, this material is suitable for use as biomass. The US South is considered to have a high rate of decay and therefore the use of residue is acceptable from this region.  Residues will not be specifically collected from the forest for biomass use in regions with slow rates of decay.

Thinnings that improve the growth, quality or biodiversity value of forests

  • In most cases the objective of thinning is to improve the growth and quality of remaining trees for saw-timber production.  Although it can also be appropriate to thin to improve bio-diversity value or to create space for new seedlings to develop.  However research shows there may be a poorer carbon outcome if biomass demand is the sole driver of thinning.

Roundwood that helps to maintain or improve the growing stock, growth rate and productivity of forests

  • The use of roundwood should not reduce the long-term production capacity or carbon stock of forests.  This means that harvested area is replaced with an equal or better-quality area of forest after harvesting. Roundwood used for biomass is commonly a biproduct of harvesting for sawtimber production.

Roundwood that helps to improve the health and quality of forests, for example by using storm, pest or fire damaged wood

  • Clearing diseased or damaged forest areas, to enable future regeneration of new forest, can be a suitable source of biomass even if the short-term carbon stock is reduced by the harvest. In some cases, clearing poor quality and low productivity stands in working forests, to establish a more productive and better-quality new stand, is also beneficial

Roundwood that is not merchantable to saw-timber markets

  • Research shows that there is a poor carbon outcome if saw-timber grade material with access to a viable market, is used for energy. This can apply to both thinnings and low grade roundwood.  However, there are some scenarios where the harvested wood fibre may have the size and quality requirements to be suitable for saw-timber but there is no economically accessible market and therefore the owner is not able to sell the roundwood as saw-timber. In this instance biomass may be the only viable market.  This is appropriate on condition that the biomass market is not sustaining elevated prices with the outcome of competing with and displacing otherwise viable solid wood product markets.

We will not use

Biomass that drives harvesting decisions that would adversely affect the long-term potential of forests to store and sequester carbon

  • In most circumstances, the objective of management in working forests is to produce saw-timber. Roundwood and residues used for biomass are by-products of this management regime.  If biomass demand was to directly cause a change in management practice (e.g. shortening rotation lengths to produce less saw-timber and more biomass) then this can have a negative consequence on the carbon storage and sequestration potential. Drax will not use biomass that causes a reduction in carbon storage, sequestration or the production of solid wood products.

Biomass that increases harvesting above the sustainable capacity of forests

  • Drax will not use biomass that causes a reduction in carbon storage, sequestration or the production of solid wood products. This is subject to independent 3rd party audit

Biomass that displaces solid wood product markets

  • Solid wood products can be effective at locking up carbon over the long-term (e.g. saw-timber for construction and furniture).  This material displaces high GHG materials (e.g. concrete, steel, plastics) and provides the most significant revenue stream for forest owners.  Biomass gives most benefit when it is an additional and supplementary market.

Biomass that comes from stumps

  • The extraction of stumps, specifically for biomass use, can cause a significant release of carbon from the soil and immediate emissions from the combustion of stumps.  There are some circumstances where the removal of stumps is necessary for pest and disease control, or for ground preparation prior to replanting. However, Drax will not use stumps for biomass feedstock. This is subject to independent 3rd party audit.

We will avoid

Damage or disturbance to high carbon forests and soils

  • High carbon forests can be defined as primary forest, virgin forest, old growth forest, designated high bio-diversity forests.  High carbon soils may include wetlands and peatlands. All the above are prohibited for biomass use under the Renewables Obligation (RO), and compliance is subject to 3rd party audit through certification schemes.

Damage or negative impact to designated or known sensitive sites or high biodiversity areas

Deforestation or degradation of the forest resource

  • Deforestation is regulated and monitored at a catchment area level. However, there can be many causes of deforestation and it is important to ensure that biomass demand is not contributing to this issue. At Drax we will evaluate all our supply chain catchment areas to ensure that our suppliers are not causing deforestation or degradation.

Being the cause of direct or indirect land use change, which would lead to an adverse climate impact

  • Drax will monitor trends in forest cover and land use within our catchment areas to ensure that biomass demand is not causing a negative climate impact as a result of land use change.

We will

Maintain the protective functions of forests and ecosystem services, including following best practice for protection of water and soil quality

  • All our suppliers adhere to local and UK regulation to protect water, soil and biodiversity. We follow Best Management Practice (BMP) as defined locally at the forest level. Minimising disturbance to ecosystems is one of the requirements of the RO. Compliance is subject to independent 3rd party audit.

Implement practices which help to reduce the risk of forest fires, pests and diseases

Promote and ensure respect for human rights through all levels of our supply chains, including safeguarding the labour rights of workers and not engaging in any form of discrimination, nor compulsory or child labour

  • This is included in existing local and UK legislation.Compliance is subject to independent 3rd party audit.

Verify that appropriate safeguards are in place to protect health and safety in the forest and at the pellet mill

  • Drax is committed to meeting or exceeding all health and safety regulations at our facilities, and has the same expectation of our suppliers. Compliance is subject to independent 3rd party audit.

Verify that legal, customary and traditional tenure and use rights of indigenous people and local communities related to the forest, are identified, documented and respected

  • This is included in existing legislation (EUTR, RO) and also in the Sustainable Biomass Program (SBP) certification Standard. Compliance is subject to independent 3rd party audit.

Verify that food and water supplies, or the subsistence needs of local communities, are not compromised due to forest biomass sourcing

  • Drax has initiated a new project to evaluate the health of the forest landscapes from which we source. This includes looking at impacts on biodiversity and socio-economic impacts on communities.  These impacts will be monitored over time with intervention projects to improve impacts if necessary. Compliance is subject to independent 3rd party audit.

Verify that our sourcing contributes to local prosperity

  •  Drax has initiated a new project to evaluate the health of the forest landscapes from which we source. This includes looking at impacts on biodiversity and socio-economic impacts on communities.  These impacts will be monitored over time with intervention projects to improve impacts if necessary.

Ensure that all biomass used is fully compliant with international and local legislation

  • This is part of existing standard practice. Compliance is subject to independent 3rd party audit.