Curtis Biomass Power Generation Plant

Complaint

In March 2019, the EIB-CM received a complaint regarding the project from two local non-governmental organisations on a number of overlapping grounds.  The complaint concerns the Curtis Biomass Power Generation Plant, consisting of construction of a 50 MWe electricity-only biomass plant located in Galicia, Spain. 

EIB-CM action

The EIB-CM's Initial Assessment Report concluded that issues raised by the complainants warranted a compliance review into the allegations.

Conclusion and outcome

The EIB-CM's analysis relative to the allegations has resulted in the following:

1. Insufficient public engagement and availability of project-related information: The complainants alleged that there was insufficient public engagement and project information available over the course of the public consultation process.

Outcome: No grounds.

2. Insufficient availability of forest residue: The complainants challenged the availability of forest residue in terms of its characteristics and sourcing area.

Outcome: The EIB-CM suggested that:

a. Concerning this project:

i. the EIB operational services liaise with the promoter with a view to obtain more information on the nature of feedstock used since launch of the operation in March 2020 in order to verify that the plant used forest residue from forest operations consisting of firewood with a small diameter, bark and other biomass waste that cannot be used in the industry and hence, is currently not collected from the ground.

ii. the EIB operational services clarify in the Environmental and Social Completion Sheet (ESCS) that, while at the moment the forest residue is likely to be sourced from within maximum 213 km transport distance from the plant, in practice, in line with EU law, it may come from further away in the EU.

b. Concerning future projects:

i. the EIB operational services develop their procedures further within one year after the closure of the case to include paying particular attention during appraisal to the fuel characteristics in biomass-related projects.

ii. the EIB operational services use the term “average transport distance” instead of the term “radius”.

3. Appropriateness of certification schemes: The complainants were concerned about the forest residue certification. The complainants considered that a minor percentage of area is suitable for certification. The complainants also alleged that the Program for the Endorsement of Forest Certification (PEFC) was a form of greenwashing created by the forest industry, without credibility.

Outcome: No grounds.

4. Negative environmental impact of the forest residue used: The complainants alleged that instead of forest residue, the promoter would rely on biomass from eucalyptus plantations. Subsequent prioritisation of planting of eucalyptus plantations would have a negative impact on the environment (e.g. biodiversity, water, climate, fire).

Outcome: No grounds.

5. Economic sustainability of the project: The complainants raised concerns about the economic sustainability of the project.

Outcome: The EIB-CM suggested that the EIB operational services clarify in the ESCS that, while one of the objectives of the regional law is to prevent forest fires, the law does not contain an exact provision requiring collection of forest residue following forest operations with the aim of preventing fires, apart from some specific cases (e.g. along highways).

Monitoring

 The EIB-CM had issued five action points when closing its compliance review in September 2021. The EIB-CM monitored and closed the monitoring process of the implementation of the action points, as per the table below:

 

Action point	Reasons for closure	Date of closure
(a) obtain more information on the nature of feedstock used by the plant	The EIB obtained the relevant information on the nature of feedstock.	October 2022
(b) clarify that the forest residue is likely to be sourced within 213 kilometers’ transport distance of the plant, in practice, in line with EU law, it may come from further away in the European Union	These action points were closed as obsolete as, due to early prepayment of the loan, the EIB will not publish the Environmental and Social Completion Sheet, which should have communicated these actions to the public.	December 2023
(c) clarify that while one objective of regional law is to prevent forest fires, the law does not expressly require the collection of forest residue following forest operations with the aim of preventing fires, apart from some specific cases		December 2023
(d) develop its appraisal procedures to specifically consider the fuel characteristics in biomass-related projects	The EIB prepared a financing note that clarifies this issue. EU legislation (e.g. Directive (EU) 2023/2413 (RED III)) also provides additional clarifications concerning this. Additional notes on this topic are in the pipeline.	April 2024
(e) use the term “average transport distance” instead of “radius	The EIB confirmed that that the term “average transport distance” will be used in future projects when referring to transport distances from feedstock sourcing areas.	October 2022