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Policy Assessment and Recommendations on Sustainable Bioenergy in Thailand By Jonas Dallinger, Kanokwan Saswattecha and Phannee Sinsuphan November 2013 Commissioned by EPFL – Ecole Polytechnique Fédérale de Lausanne For more information: Anne-Sophie Dörnbrack EPFL Energy Center Château de Bassenges - Station 5 1015 Lausanne, Switzerland http://energycenter.epfl.ch Aidenvironment Barentszplein 7 1013 NJ Amsterdam The Netherlands + 31 (0)20 686 81 11 [email protected] www.aidenvironment.org
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Page 1: Policy Assessment and Recommendations on Sustainable ...

Policy Assessment and Recommendations on Sustainable Bioenergy in Thailand

By Jonas Dallinger, Kanokwan Saswattecha and Phannee Sinsuphan

November 2013 Commissioned by EPFL – Ecole Polytechnique Fédérale de Lausanne For more information: Anne-Sophie Dörnbrack EPFL Energy Center Château de Bassenges - Station 5 1015 Lausanne, Switzerland http://energycenter.epfl.ch Aidenvironment Barentszplein 7 1013 NJ Amsterdam The Netherlands + 31 (0)20 686 81 11 [email protected] www.aidenvironment.org

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Table of Contents

List of Abbreviations 3

Introduction 5

1. The status and potential of Bioenergy in Thailand 5 1.1 The Alternative Energy Development Plan 7 1.2 Biodiesel 9 1.3 Ethanol 13 1.4 Electricity from biomass 16

2. Sustainability issues in the Thai bioenergy sector 21 2.1 Environmental issues 22 2.2 Social issues 25

3. Thai regulations related to the sustainability impacts of bioenergy 30 3.1 Considering environmental impacts 32 3.2 Considering social impacts 34 3.3 Regional approaches 36

4. Recommendations 38 4.1 Environmental safeguards 38 4.2 Social safeguards 40

5. Conclusions 43

References 47

Appendices 55 Appendix 1. List of stakeholders interviewed 55 Appendix 2. Key stakeholders on sustainable bioenergy in Thailand 56

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List of Abbreviations

AEDP Alternative Energy Development Plan ASEAN Association of Southeast Asian Nations BOI Board of Investments BtL Biomass to Liquid CPO Crude Palm Oil DEDE Department of Alternative Energy Development and Efficiency EIA Environmental Impact Assessment GDP Gross Domestic Product GHG Greenhouse Gas HBD Hydrogenated biodiesel MoAC Ministry of Agriculture and Cooperatives MoE Ministry of Energy NGO Non-governmental Organization ONEP Office of Natural Resource and Environmental Policy and Planning MONRE Ministry of Natural Resources and Environment RSB Roundtable on Sustainable Biomaterials RPO Refined Palm Oil SPP Small Power Producers THB Thai Baht VSPP Very Small Power Producers

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Introduction

This report is part of a project by the Swiss Federal Institute of Technology Lausanne (EPFL) and funded by the Swiss Agency for Development and Cooperation. Within this project, EPFL aims at providing support to selected governments in developing countries to develop and implement regula-tions and policies for sustainable biofuels/bioenergy production, based on the Roundtable on Sus-tainable Biomaterials (RSB) Principles and Criteria.

EPFL commissioned Aidenvironment to conduct a review of sustainability regulations related to biofuels/bioenergy in Thailand and to assess, by conducting interviews and a stakeholder outreach meeting, whether there is a need for improving such regulations and/or their implementation.

Based on desk research and interviews with key stakeholders from the Thai Bioenergy industry, Thai government as well as civil society, Aidenvironment analyzed the status of Thailand’s bioenergy and related regulations. Furthermore, existing issues regarding the sustainability of bioenergy and how they are addressed by the regulatory framework in Thailand, were assessed.

1. The status and potential of Bioenergy in Thailand

Thailand is in a good position to establish a bioenergy industry. Much feedstock is readily available, as Thailand is a major agricultural producer and a leader in the production of crops like sugarcane,

cassava and rice.1 Agriculture provides a significant source of income for Thailand, employing 40.7% of Thailand’s labor force and accounting for 13% of Thailand’s GDP. Smallholders dominate agricul-

tural production and the provision of agricultural labor2. Although agricultural production per hec-tare in Thailand is currently low for many crops, when compared with international standards - there

is great potential for increased feedstock production without expansion of agricultural areas.3 Thai-

land is aware of this potential and aims to become the regional biofuels hub in South East Asia.4

High dependency on fossil fuels. Currently, more than eighty percent (80%) of Thailand’s total ener-gy consumption is based on fossil fuels. As depicted in Figure 1, crude oil accounts for the biggest share (39%) followed by natural gas (31%) and coal (13%). Another significant share of the total ener-gy consumption is generated from solid biomass and waste (16%). Only one percent (1%) is produced by hydropower sources and less than one percent (0.7%) by liquid biofuels.

1 FAO (2009).

2 Salvatore and Damen (2010).

3 Damen (2010).

4 The Nation (2011).

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Figure 1: Total energy consumption in Thailand by source (2010)

Source: EIA 2013, p. 2

Thailand is heavily dependent on oil imports for its crude oil consumption - importing eighty-five percent (85%) of the crude oil it requires. Domestic production mainly stems from offshore facilities in the Gulf of Thailand. Producing close to a seventy percent (70%) share in Thailand’s oil produc-

tion, offshore exploitation is dominated by the multinational energy corporation Chevron.5

Electricity consumption is growing steadily, with an average rate of five percent (5%) over the last ten years. Approximately sixty percent (60%) of the electricity generation is from natural gas fired generation. Although Thailand has a significant production volume of natural gas, which has doubled since 2000, gas reserves in Thailand are expected to peak in 2017. To meet the ever-growing demand for electricity generation, additional gas has been imported from Myanmar since 1999.

Thailand is a front runner in bioenergy development in the region. With projects having been initiat-ed in the 1980s, Thailand is the first country within the Association of Southeast Asian Nations

(ASEAN) to introduce ethanol based fuel.6 To address both the strong dependency on imports and declining domestic fossil fuel resources, the Thai Ministry of Energy has been promoting the use of renewable energies since 2000. In addition, when fossil fuel prices started to experience strong rises

in 2004, the national market for biofuels began growing rapidly.7 Strategic goals for gasohol and

biodiesel development were developed in 2003 and 2005 respectively.8

The following sections provide an overview of the status and potential of bioenergy. Based on this, the report gives insights into existing sustainability issues in the Thai bioenergy sector and how those are addressed by Thai regulations.

5 EIA (2013).

6 FAO (2009).

7 EIA (2013).

8 Morgera (2009).

Crude Oil; 39%

Natural Gas 31%

Coal; 13%

Solid Biomass & Waste; 16%

Hydroelectric Power; 1%

Biofuels; 1%

Crude Oil

Natural Gas

Coal

Solid Biomass & Waste

Hydroelectric Power

Biofuels

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1.1 The Alternative Energy Development Plan

Thailand’s renewable energy strategy. Thailand has set out a national framework to spur on renew-able energy development. Developed by the Thai Ministry of Energy, the Renewable and Alternative Energy Development Plan (AEDP) 2012-2021, targets an overall share of twenty-five percent (25%) for renewables in the country’s energy mix by 2021.

Through the AEDP, Thailand aims to decrease its dependency on energy imports. The AEDP has three main objectives in terms of promoting renewables. Firstly, energy imports constitute a signifi-cant portion of Thailand’s foreign trade balance, accounting for approximately ten percent (10%) of

Thailand’s Gross Domestic Product (GDP).9 The reduction of energy import dependency is thus the main reason for Thailand’s promotion of renewable energy sources. Secondly, promoting renewable energy sources aims to reduce the high share (over 70%) of natural gas in the overall energy mix. Thirdly, as mentioned in the AEDP, Thailand aims to reduce greenhouse gas (GHG) emissions and

move towards a low carbon society.10

Investments are needed to realize the AEDP. By implementing the AEDP, the Thai government an-ticipates reductions in oil imports of 574,000 million Thai Baht THB (19 billion USD) per year and CO2 emission reductions of 76 million tons/year within 2021. At the same time, the AEDP is ex-pected to encourage private sector investment of approximately 442,000 million THB (14.7 billion

USD).11 To encourage investments in alternative energies, the Thai Board of Investments (BOI) pro-vides a number of incentives. These incentives include corporate tax, import tariff reductions and exemptions, foreign land ownership, foreign currency remittances, deductions in electricity, trans-

portation and water costs, as well as adjusted accounting requirements.12

The AEDP promotes the use of different types of renewable energy sources, as outlined in Figure 2. Relevant for this report are the categories of renewable energy sources: (1) Bioenergy, as electricity from biomass and electricity from biogas; (2) Biofuels, namely ethanol and biodiesel; and (3) the category “New Energy Replacing Diesel”, which is concerned with second-generation biofuels.

9 FAO (2009).

10 DEDE (w.y.).

11 Haema (2012).

12 BOI (2012).

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Figure 2: The Thai Renewable and Alternative Energy Development Plan 2012-2021

Source: Based on TEMA (2013).

The AEDP has recently been updated with the following policy goals: Table 1 : Development of Renewable Energy Plan

Energy source PDP 2010 (MW)

AEDP 2012 (MW)

AEDP 2013 (MW)

Hydro 263 1,608 324 Wind 798 1,200 1,800 Waste 173 160 400 Bio Gas 121 600 3,600 Bio Mass 2,340 3,630 4,800 Solar 923 2,000 3,000 Others 3 3 Total 4,618 9,201 13,927 Source : EGAT, IQ Biz The targets for biofuels are contested and during the process of researching and writing this report have changed several times. According to the latest, unofficial communication with an officer from the Ministry of Agriculture and Cooperatives (MoAC), the target for new energy replacing diesel has been reduced to 0.30 mio l/day, while the target for conventional biodiesel (B100) has been in-creased to 7.2 mio l / day. As biodiesel, ethanol and electricity from biomass (bioenergy) are considered most relevant for this report, the respective sector specific policies will be discussed separately in the sections below. Table 1 gives an overview of policy targets for bioenergy, current production as well as the current and planned agricultural production areas for the main feedstocks.

Alternative Energy Development Plan (AEDP: 2012 – 2021)

Target on using Alternative Energy at 25% of Total Energy Consumption by 2021

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Table 1: Overview of policy goals and the current status bioenergy production13

Type of bioen-

ergy / biofuel

Production Main feedstocks

used

Production Area

Current Policy tar-

get

(2021)

Current Policy target

Ethanol 2.5 mio l/day

9 mio l/day Molasses from sugarcane (80%)

8 mio rai Under revi-sion

Cassava (15-20%) 8.6 mio rai Under revi-sion

Second-generation HBD

None 25 mio l/day

Palm oil, algae none

Biodiesel 2.74 mio l / day

5.97 mio l/day

Palm oil (CPO (~80%) / stearin)

4.3 mio rai 7.8 mio rai

Electricity from biomass

1818 MW 4,800 MW Bagasse (~60%) By-product

Rice husks (~10%) By-product

Electricity from biogas

138 MW 3,600 MW

Source: Aidenvironment

1.2 Biodiesel

Current situation, trends and policy targets Biodiesel production in Thailand is based on oil palm. Conventional biodiesel is produced in a chem-ical process called transesterification. Transesterification traditionally uses refined palm oil (RPO) as the main feedstock. Other palm oil based feedstocks for biodiesel used in Thailand are Fatty Acid Distillate and Refined Palm Stearin. They are of lower quality than RPO, however, but are especially

interesting due to their nature as a by-product from palm vegetable oil production.14 Figure 3 below depicts the life cycle system for palm oil based biodiesel production.

13

FTI (2013). 14

Chonsaranon et al. (2006); personal communication Sanin Triyanond (2012).

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Figure 2: Life cycle system for palm oil based biodiesel production

Source: Pleanjai & Gheewa (2009).

There is significant underutilization of capacity among all Thai biodiesel producers. This is shown in table 2. The maximum utilization capacity of plants is currently forty-five percent (45%), and some

plants have suspended their operations.15 Currently, fourteen (14) biodiesel production plants are operational in Thailand, with a combined production capacity of 5,955,800 liters of biodiesel (B100) per day. Table 2 lists the companies, their average production in 2009 and their respective produc-tion capacities. Despite the current underutilization of production capacity, investment in biodiesel production is still ongoing. An example is the investment of Bangchak Petroleum PCL in a second biodiesel production plant. The investment will increase their production capacity to 600,000 liters of biodiesel per day. Bangchak Petroleum PCL is also considering investing upstream in palm oil

processing.16

15

Green Power Corporation (2009). 16

Bangkok Post (March, 2012).

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Table 2: A list of biodiesel plants in Thailand and their capacities

Processing Plant Location Production Capacity (liters/day)

Average Actual Pro-duction (liters/day) in Nov. 2009

1. Bangchak Petroleum 2. Bioenergy Plus 3. Absolute Energy 4. Patum Vegetable Oil 5. Bankok Alternative Energy 6. Green Power Corporation 7. A.I. Energy 8. Weerasuwan 9. Thai Oleo Chemical 10. New Biodiesel 11. Pure Biodiesel 12. Siam gulf Petrochemical 1/ 13. E-Ether 14. Bangchak Biofuel 2/

Bankok Ayudhaya Prachinburi Patumthani Chachoengsao Chumporn Samutsakorn Samutsakorn Rayong Suratthani Rayong Petchaburi Chiang Rai Ayudhaya

50,000 100,000 800,000 1,400,000 200,000 200,000 250,000 200,000 685,800 220,000 300,000 1,200,000 50,000 300,000

2,967 0 188,724 576,989 41,667 90,203 41,173 11,185 307,000 93,162 111,787 0 1,300 0

TOTAL 5,955,800 1,466,157

Source: Preechacharn (2010).

The utilization of by-products from oil palm production is on the rise. Besides underutilizing their capacities, biodiesel producers suffer from low prices in an oligopolistic market environment. A few petroleum oil refineries constitute the only market outlet for biodiesel producers. It has been report-ed that biodiesel producers are selling below their production cost at times. Price pressure leads to a higher demand for Stearin as a feedstock for biodiesel production and the alignment of Crude Palm

Oil (CPO) and Stearin prices.17 The profitability of biodiesel production is strongly influenced by the retail price of diesel and the price of the feedstock used. On average, seventy to eighty percent (70-

80%) of the production cost of biodiesel is from the palm oil production cost.18

Policy on biodiesel The AEDP includes ambitious policy goals for biodiesel. By 2021, the daily biodiesel production (B100) is targeted to reach 5.97 million liters. However, the AEDP does not mention any time bound milestones towards the achievement of this goal. The demand for biodiesel is managed by a mandato-ry blending of conventional diesel with biodiesel. Currently, five percent (5%) of B100 has to be

blended. For 2014, the quota is planned to increase to seven percent (7%)19. In general, the plans aim at managing the blending quota in accordance with the domestic palm oil production. This has been the case in the past where blending quotas and targets have been adjusted quickly in response to demand or supply shocks in palm oil production. Currently, blending beyond five percent (5%) is being discussed among automobile manufactures - some of whom are reluctant to agree on a higher blending quota. The AEDP mentions the goal to develop a biodiesel standard that would allow a blending of up to seven percent (7%). For ships and trucks, higher blending mandates (B10 or B20) are being considered and implementation is being tested in pilots.

The biodiesel production goal, together with the goal for second-generation biofuels, pose a high demand for increasing palm oil production in Thailand. The MoAC is currently developing a new National Palm Plantation Plan (2013-2017) to achieve the goals of area expansion, increased yields and the higher oil extraction rate (OER). To support the supply of biodiesel, the AEDP foresees the increase in the area planted with oil palm to reach 5.5 million rai (880,000 hectare) in 2021. For

17

Preechacharn (2010). 18

Prasertsri and Kunasirirat (2009). 19

Preechacharn and Prasertsri (2013).

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agricultural production of oil palm crops, goals are set at 3.2 tons of Fresh Fruit Bunches (FFB) per

rai20 per year (20 t/ha/year). The OER is set at least eighteen percent (18%)21. The capacity of CPO production in Thailand is foreseen to reach at least 3.05 million metric tons per year. Trends in FFB productivity and the OER over the last 20 years are shown in Figure 4. The goal for hydrogenated biodiesel (HBD) production from palm oil will be directly linked to the demand for palm oil produc-tion and the area needed for production.

Figure 3: Trends in Fresh Fruit Bunches (FFB) productivity and Oil Extraction Rates (OER) in Palm Oil Production in Thailand

Source: Based on OAE (2012).

New energy replacing diesel Achieving the policy goals for new energies replacing diesel is the main challenge of the AEDP. Sec-ond generation biofuels are currently not in use in Thailand. Promotion of “New Energy Replacing Diesel” as mentioned in the AEDP, has until now focused on research and development as well as the implementation of pilot projects. According to the AEDP, commercial production is planned to start in 2018. The Thai government initially expected those new technologies to contribute significantly to the overall liquid biofuels production of the country. As mentioned above, the target for new energy replacing biodiesel has been drastically reduced during the writing of this report. Discussions with the Department of Alternative Energy Development and Efficiency (DEDE) officers show that poten-tial feedstocks for these second generation biofuels are currently being considered. The MoAC states that the most realistic scenario to achieve the 2021 goal is to use palm oil and algae to produce hy-drogenated biodiesel (HBD). HBD from algae oil could contribute 10 l/day and HBD from palm oil could contribute 12 l/day, according to current plans. An additional 2.3 l/day could come from algae biomass, using Biomass to Liquid (BtL) technology. Different scenarios to achieve the ambitious goal are still under consideration. As Thailand has no experience in producing biofuels from algae, this will not be further discussed in the present report.

To provide the additional feedstock needed for HBD production, different scenarios are currently being evaluated and discussed among officers of the MoE and the MoAC. The scenario which is con-sidered the most realistic, would require an increase in the area planted with oil palm of to up to 7.8 million rai (1.25 million ha). The goal is to achieve this by 2017. Under this scenario, a further in-

20

1 hectare equals 6.25 rai. 21

Recent discussions (September 2013) suggest that these figures have been increased to 3.5 t FFB/ha and OER of 18.5% but this has not been officially confirmed.

10.0%

12.0%

14.0%

16.0%

18.0%

20.0%

22.0%

5.00

7.00

9.00

11.00

13.00

15.00

17.00

19.00

21.00

FFB production t / ha

OER %

Linear (FFB production t /ha)

Linear (OER %)

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crease in the FFB yield to 3.39 ton/rai/year (21.2 t/ ha) would be necessary to reach the demand for CPO, considering an OER of seventeen percent (17%).22

Several of the interviewed stakeholders criticized the goal of producing 25 l/day from such new tech-nologies, as the implementation of the new technologies in such a fast pace might be overambitious and not feasible. The government expects the national petroleum company, PTT Public Company Limited, which is mainly owned by the Ministry of Finance, to develop the HBD technology in Thai-land in the coming years. The advantage of HBD is that it allows a much higher admixture to conven-tional fuels without major adjustments from car manufacturers. It can also be used as a jet fuel.

In addition, the AEDP mentions the use of ethanol to achieve the second generation biofuels target. Blending ethanol with an additive (ED95) does allow its use in diesel vehicles. The new technology is currently being tested in cooperation with a European bus manufacturer in public buses. HBD from palm oil will ultimately add to the rising demand for palm oil production and hence has similar im-plications to fatty acid methyl ester (FAME) biodiesel, which is a first generation biofuel.

1.3 Ethanol

Current situation, trends and policy targets Thailand aspires to become the ethanol hub of Asia and is already exporting. Ethanol production has been promoted in Thailand since the 1980s, initially by a Royal project. The domestic demand of 1.3 million liters of ethanol per day is easily met by the current production capacity of 3.5 million l/d. Although exporting ethanol does require a special permit from the Thai Ministry of Commerce, Thai-land exports considerable amounts of ethanol. Half of the exports are destined to the Philippines and Japan. South Korea and Taiwan are other export markets.23 Table 3: Thai Ethanol Exports in million liters

Year 2007 2008 2009 2010 2011 2012

Jan. - 5.58 5.24 2.43 10.40 16.300

Feb. - 18.18 1.83 9.63 7.32 56.350

March - 0.84 - 4.31 4.93 39.305

April 0.35 8.22 - 8.40 25.77 26.200

May - 5.21 0.30 2.10 4.22 10.860

June - 8.15 0.09 0.09 0.71 19.250

July 0.36 2.45 0.19 3.83 14.18 13.625

Aug. 2.50 3.30 - 7.50 16.00 29.55

Sept. - 5.87 0.09 0.14 14.90 28.00

Oct. 3.16 3.00 - - 11.30 23.90

Nov. 3.79 5.00 2.61 7.65 14.75 13.30

Dec. 4.74 - 5.27 2.10 14.80 27.23

Total 14.90 65.80 15.62 48.18 139.28 303.870

Source: Department of Customs

Currently, twenty-one ethanol production plants are operating in Thailand. They have an overall production capacity of 3.52 million l/d. Fifty-one percent (51%) of this capacity was used in 2012.

22

DEDE (2013). 23

Sapp (2012).

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Whereas plants using molasses from sugar production as a feedstock could use around eighty percent (80%) of their capacity, producers relying on cassava only used forty percent (40%). This is due to higher prices for cassava feedstock and a more expensive production process in ethanol plants using cassava. Figure 4 gives an overview of the ethanol plants currently operating in Thailand, their loca-tion and the type of feedstock used. The overall capacity for ethanol production is set at 59% from molasses, 20% from cassava, 15% from both molasses and cassava and to 6% directly from sugar-cane.24 Table 4: Thai Ethanol Plants in Operation in 2012

Plants Province Feedstock used Capacity (liter/day) Mitrphol Biofuels Chaiyaphum Molasses 230,000

Mitrphol Biofuels Kalasin Molasses 230,000

Mitrphol Biofuels Suphanburi Molasses 200,000

Ekarat Pattana Nakhon Sawan Molasses 230,000

Thai Agro Energy (phase1)

Suphanburi Molasses 150,000

Khon Kaen Alcohol Khon Kaen Molasses 150,000

Thai Rung Rueng En-ergy

Saraburi Molasses 120,000

Thai Sugar Ethanol Kanjanaburi Molasses 100,000

KI Ethanol Nakhonrajasima Molasses 100,000

Pornwilai Internation-al

Ayutthaya Molasses 25,000

Thai Alcohol Nakhon Prathom Molasses 200,000

Khon Kaen Alcohol Kanjanaburi Molasses 200,000

E.S. Power Sa Keaw Molasses/Cassava 150,000

Rajburi Ethanol Rajburi Molasses/Cassava 150,000

Thai Agro Energy (phase 2)

Suphanburi Molasses/Cassava 150,000

Double A Ethanol Prajinburi Cassava 250,000

Sap Thip Lopburi Cassava 200,000

P.S.C Starch Products Chonburi Cassava 150,0000

Thai Ping Sa Kaeo Cassava 150,000

Thai Ethanol Power Khon Kaen Cassava 130,000

Mae Sod Clean Energy Tak Sugar Juice 200,000

Source: Based on TEMA (2013).

Production is expected to increase by thirteen (13%) in 2013, driven by export demand from China and the Philippines. As domestic demand has been limited and plants are operating at only half of their capacity, the Thai ethanol sector is seeking to further expand its export markets.25 Four addi-tional plants are planned and expected to start operating in 2013. Three of them will use cassava as a feedstock, and the other one could use molasses and cassava. The fact that despite overcapacities in production new investments in ethanol still takes place could be the result of expected high demand in the future.26

24

There is only one plant in Thailand designed to produce ethanol from sugar juice. This requires a special license which has been given to allow the production of ethanol from sugarcane grown on contaminated soil in a certain area which has been affected by mining opera-tions. 25

Phoonphongphiphat (2012). 26

TEMA (2013).

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Ethanol from molasses. Ethanol production is closely integrated with the sugar industry. Sugar pro-ducers started to set up ethanol plants to add value to the molasses. Molasses is a by-product in sugar production and was considered a waste product a decade ago. Molasses is also used as a supplement in animal food. The processing of one ton of sugarcane will produce 42.5 kg of molasses (4.25%). With almost 100 million tons of sugarcane produced in Thailand in 2012, 4.25 million tons of molas-ses were available. Of the latter, roughly fifty percent (50%) is used for the production of liquor and forty percent (40%) for the production of fuel ethanol. The rest is exported or used for animal feed production. Figure 4 gives an overview of the products that can be derived from sugarcane in an inte-grated production system. Figure 4: Molasses based ethanol production from a biorefinery complex

Source: Gheewala et al. (2011).

Roughly seventy percent (70%) of sugarcane production comes from small-scale farms in Thailand. Sugar producers possess limited land resources to produce their own feedstock and rely heavily on the surrounding farmers to supply their sugar mills. Buying land is difficult for sugar producers, due to its limited availability and high investments requirements.

Ethanol from cassava. Cassava is a suitable feedstock for biofuels. This is due to its features regard-ing soil and climate requirements, regional availability, the high potential for increasing its produc-tivity and its role as a subsistence crop in many poor countries. In Thailand, however, it is mainly exported or used in food processing (see below). In contrast to sugarcane, cassava can be harvested throughout the year. It can also be easily stored in the form of dried cassava chips.27

Thailand is the largest producer and exporter of cassava in the world with an annual production of more than 29 million tons in 2012 and more than 535,000 households are involved in cassava culti-

27

Elbehri et al. (2013).

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vation. Twenty-three percent (23%) of the Thai cassava production is sold on the domestic market, while seventy-seven percent (77%) is exported in different forms, mainly cassava chips (2012). Six-teen percent (16%) of the total production is used to produce cassava flour, five percent (5%) is used for animal feed and two percent (2%) is used to produce energy. The potential for expansion of pro-duction is considered large. The Thai Board of Investment estimates the capacity of cassava based ethanol production at 7.3 million l/d.28 In Thailand, cassava is mainly being produced in small-scale agriculture, and the additional demand for the feedstock to produce ethanol provides an outlet for farmers in times of low or fluctuating prices and also contributes to rural economic growth.29

Policy on ethanol The policy target for ethanol production is set at 9 million l/d by 2021 in the AEDP. This is support-ed by demand side measures (see below) and the promotion of increased yields for cassava and sug-arcane. The aim is to achieve a sugarcane production of 105 million metric tons per year, on a planted area of 7 million rai (1.12 million hectares). For cassava, the aim is to produce 35 million metric tons per year on the same size of planted area as foreseen for sugarcane. The policy aims at encouraging necessary feedstock production on existing agricultural land.

To support the consumption of ethanol based fuels, regular octane 91 petrol was phased out in Thai-land by the end of 2012.30 All regular petrol (91 octane) has to be mixed with ten percent (10%) etha-nol. The ethanol component within the gasohol mix receives certain tax benefits which allows a lower price for the gasohol compared with regular gasoline. Contributions to the Oil Fund31 are also lower for gasohol sales.32 Regular petrol (octane 95) is still available at Thai petrol stations to accommodate the concerns of owners of old cars and motorcycles. However, octane 95 petrol is reported to account for below five percent (5%) of the overall fuel consumption in transportation and there are plans to phase out the fuel completely in future. E20, a mix of ethanol and gasoline with a twenty percent (20%) ethanol content, is supported by setting its price at 2 THB/l lower than 91 gasohol (E10). The government also promotes research into new technologies allowing higher blending ratios with etha-nol. Excise tax is reduced for manufactures of eco cars and cars with the technology to use E8533.

1.4 Electricity from biomass

Current situation, trends and policy targets Currently, 142 biomass based electricity generating plants are operating in Thailand. Their overall electricity generation in 2012 accounted for 1989 MW. Twenty five (25) plants have a capacity of between 10 and 90 MW and are considered Small Power Producers (SPP), whereas 74 have a capacity of 10 MW or lower and are considered Very Small Power Producers (VSPP). Another 43 plants pro-duce electricity for consumption in companies’ own plants (off-grid) and hence they do not sell the electricity to the grid. Table 3 gives an overview of the feedstock used by biomass power plants of different sizes.

28

Leonardo and Lazarus (2010). 29

Elbehri et al. (2013). 30

Bangkok Post October (2012). 31

A state fund established since 1973 and used to stabilize fuel prices in Thailand. The Oil Fund is fed by the Oil Fund Tax which is levied on importers and domestic producers. 32

Morgera et al. (2009). 33

E85 is a gasohol mix containing 85% of ethanol

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Table 4: Solid biomass feedstocks for electricity generation in Thailand

Feedstock SPP VSPP Off-grid Sum Bagasse 309.4 746.7 105.85 1161.95

Rice hull/husk 48.3 122.29 15.45 186.04

Bagasse, wood bark, rice hull/husk, others

134.9 - - 134.9

Rice hull/husk, wood fragment, others

82.3 - - 82.3

Wood tar oil, wood bark, wood fragment

87.2 - - 87.2

Para rubber fragment

23 - - 23

EFB, palm fiber, palm shell

9.9 30.5 33.84 74.24

Wood waste/saw dust

- 0.6 - 0.6

Coconut husk - 8 - 8

Corncob - 0.16 - 0.16

Wood fragment - 17.3 14.1 31.4

Other husks - 68 - 68

Coal and biomass - - 131.056 131.05

Total 1988.84

Source: DEDE, internal document (2013).

Bagasse, generating fifty eight percent (58%) of the total energy from biomass in 2012, is by far the most important feedstock used, followed by rice husk and a mix of biomass residues with bagasse. Figure 5 (below) summarizes (under ‘others’) different types of biomass mixes used by the plants in Thailand, which include biomass from the palm oil, rubber, coconut and sawmill industries. The RSB considers bagasse and most of the other biomass feedstocks currently used in Thailand as by-products, which have certain sustainability advantages compared with other bioenergy feedstocks 34.

34

RSB (2012).

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Figure 5: Main biomass feedstocks used for electricity generation in Thailand

Source: DEDE, internal document (2013).

Policy on electricity from biomass Besides providing investment incentives as outlined above, electricity from biomass is promoted by the Small Power Producer (SPP) and Very Small Power Producer (VSPP) programs. Small-scale pow-er producers generating electricity from biomass or biogas35 can sell electricity to the power grid and receive a subsidized price, the so called “adder”, based on the source of the electricity and the size of the generating plant. The promotion of renewable energy for electricity generation distinguishes between VSPP with up to 10 MW of production capacity and SPP with a production capacity of be-tween 10 and 90 MW, with a higher adder being paid to the VSPP. Within the VSPP category, another differentiation is made for the adder for different sources of alternative energy, with the smaller facil-ities always receiving a higher adder.

The current adder for electricity from biomass is 0.5 THB/kWh for VSPP facilities with an installed capacity of 1 MW or less and 0.3 THB/kWh for facilities with an installed capacity of more than 1 MW. The adder for SPP is based on a bidding process. Electricity from biogas receives the same adder premiums as electricity from biomass.36 Investors in alternative energy projects also receive support from the Energy Services Company (ESCO) Fund which provides guarantees to lending institutions of investor’s loans.

The 2021 target for electricity generation from biomass is 3,630 MW with a current total installed capacity of 1,818 MW. Considering the power purchase agreements that have already been signed as well as the proposals for projects to generate electricity from biomass which have been approved and submitted, in addition to the current capacity – the overall expected capacity is 4,012 MW which is beyond the policy goal in the AEDP. 37 Besides the adder and investment incentives as the main instruments to achieve increased generation of electricity from biomass, the MoE plans to promote the plantation of fast growing trees as a feed-stock, the production of pellets from biomass to reduce logistic costs and to implement better tech-

35

As well as municipal solid waste, wind, solar or mini hydropower plants, which are not considered in this report. 36

Haema (2012). 37

FTI (2013).

58%

9%

7%

19%

7%

Bagasse

Rice Husk

Bagasse mix

Others

Coal+Biomass

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nology in power plants to increase their efficiency. As the capacity of the current grid to take up and distribute the energy produced from biomass is limited, the improvement of the grid infrastructure is another measure that the government seeks to promote to assist in the growth of power generation from biomass in areas with a high feedstock potential. It is currently not certain which specific measures will be taken to achieve the goals of increased electricity generation from biomass.

The 2021 target for electricity produced from biogas is set at 600 MW. The current capacity is 138 MW (2013). The MoE promotes local consumption and the establishment of community systems for using biogas as well as further research and investment on enabling the use of biogas in the transpor-tation sector.38

38

DEDE (w.y.).

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Project number Error! Reference source not found. 21

2. Sustainability issues in the Thai bioenergy sector

To assess the sustainability issues in the Thai bioenergy sector, the RSB Principles and Criteria have been used as the assessment framework. The assessment is based on interviews with a number of key stakeholders (a list of interviewed people is in Annex 1), available studies and reports as well as the outcomes of a policy forum with more than forty participants which was organized in Bangkok in September 2013. The workshop report is available on the EPFL Energy Center website (http://energycenter.epfl.ch/page-94149-en.html). The research involved approaching a number of non-governmental organizations (NGOs) to provide input, however with limited response. An affect-ed community was contacted and a follow-up interview with the Healthy Public Policy Foundation gave further insights into the concerns regarding the impacts of biomass based power plants. Cur-rently, the number of NGOs working on bioenergy sustainability, and the impacts of the Thai bioen-ergy policy on society and the environment, are limited. Despite the efforts made to identify and ac-cess potentially affected stakeholders, it is acknowledged that a large number of affected parties could exist which lack organization and representation to make their voices heard and hence could not be considered in this report.

In the following section, the main sustainability issues associated with the Thai policy on bioenergy will be discussed. Issues could arise from feedstock production for bioenergy as well as during the processing steps of such feedstocks. Secondary research as well as stakeholder interviews with repre-sentatives of the Thai government, industry, development organizations and a representative from an affected community (see Annex 1), have been used to gain an overview of the main issues. Table 5 summarizes in a qualitative manner the main sustainability risks related to bioenergy production in Thailand. In the following sections the different scores for each of the sustainability issues will be explained on the basis of the available evidence and best professional judgments. Table 5: Main sustainability risks in the Thai bioenergy sector Sustainability is-sues

Production of feedstocks Processing Palm oil Sugarcane Cassava Bioethanol Biodiesel Electricity

from Bi-omass

1. Social issues Rural develop-

ment Land Rights Human and La-

bor Rights Food Security

0 + + +

+ 0 + +

0 0 0 0

0 0 0 0

0 0 0 0

+ 0 0 0

2. Environmental issues Soil Water Air GHG Conservation

+ + 0 + ++

+ + ++ 0 +

++ 0 0 0 0

0 ++ 0 0 0

0 + 0 + 0

0 ++ + 0 0

++ strong evidence of sustainability risk + some evidence of sustainability risk 0 no evidence

Source: Aidenvironment

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2.1 Environmental issues

Soil Soil erosion and depletion are a major concern in Thailand and an issue that the Thai MoAC is well aware of. The Land Development Department reports that thirty-three percent (33%) of Thai agricul-tural land is affected by soil erosion and depletion, which involves the loss of nutrients and soil or-ganic matter. Mismanagement of agricultural land is seen as the reason for soil erosion and deple-tion. Low organic matter content in soils is reported for almost sixty percent (60%) of the country.39

Although increased soil erosion and soil depletion cannot be directly accounted for by the production of feedstock for bioenergy, it is an issue that requires thorough attention for bioenergy projects using agricultural feedstocks. Cassava production in particular faces problems with soil erosion as the soil cover is low and deep tillage is commonly used for harvesting. Planting on steep land will amplify the problem.40

Managing agricultural residues is an important aspect in the management of soil health and in in-creasing the organic matter content of soil. The use of agricultural residues to generate electricity could lead to the removal of more of those residues, for example, in the case of rice husks which con-stitute an important feedstock for bioenergy in Thailand. Community representatives expressed con-cerns about the declining availability of agricultural residues to be used for the production of organic fertilizers. During the policy forum this issue was raised as well and participants expressed the need for solid research to assess the most economically viable and sustainable use of agricultural residues. Results from such research would play an important role in convincing farmers to apply practices on using agricultural residues for the management of soil quality.

For oil palm and sugarcane as perennial and semi-perennial crops, soil erosion is less of a concern; however, adequate soil management is also necessary for those crops, especially during the estab-lishment phase of oil palm plantations and during the harvesting of sugarcane.

Soil stability and soil organic matter are relevant requirements in the RSB framework for bioenergy produced from by-products41. This is most relevant in the Thai context for ethanol produced from molasses, biogas produced from wastewater in the sugar and palm oil industries as well as electricity generation from rice husk and bagasse.

Water Water use, as one of the sustainability concerns raised in the RSB Standard, is very much related to the overall agricultural landscape of Thailand. In general, it is reported that water use in agricultural production as well as wastewater in processing are major concerns in the sugar industry42. The Alter-native Agriculture Network reports that increased cultivation of sugarcane on land previously used for traditional agricultural cropping systems like rice for self-sufficiency can have negative effects on local water sources and related ecosystems due to increased application of fertilizer and agro-chemicals43. With a well-developed sugar industry in Thailand, bioenergy production from sugarcane is mainly based on by-products, namely molasses for ethanol production and bagasse for electricity generation. Using by-products is considered good practice by the RSB standard system, as it can lead to reduced pressure on land from biofuel specific demand. There is one exception in Thailand where ethanol is directly produced from sugar juice. This exception has been given on an area of land which

39

LDD. 40

Elbehri et al. (2013). 41

RSB (2012). 42

Elbehri et al. (2013). 43

AAE (2009).

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is contaminated due to previous mining activities. The sugarcane produced on this land cannot be used for food production as this might cause health risks to consumers

In the processing steps of biofuels production, water has been reported as a sensitive issue. One af-fected community reported that the set-up of a power plant to generate electricity from biomass and the related establishment of a large water pond reduced the water availability in the nearby commu-nity. This report could not be confirmed and whether this is a single case or if further communities are affected, would require more investigation. However, it clearly points to the importance of con-sidering and assessing the impacts of feedstock processing on water availability – where large amounts of water are used, for example in power plants, sugar mills and palm oil mills.

A major environmental concern in bioenergy production is the wastewater produced from processing plants and its potential release into local water sources. This can have adverse effects on the health of affected ecosystems and the people who depend on those ecosystems respectively, where no proper wastewater treatment takes place. The case of one ethanol plant inappropriately treating wastewater and illegally releasing insufficiently treated wastewater has been reported to have caused serious environmental and health impacts.44 Air Regarding the agricultural production of feedstocks for bioenergy, the burning of agricultural resi-dues was reported as a severe problem during the interviews conducted. In particular during sugar-cane cultivation, pre-harvest burning of the cane is a common practice among small-scale farmers to reduce the required labor input. As external labor is used during the harvesting period, pre-harvest burning is often a prerequisite for finding labor because laborers are not willing to take on the burden of cutting unburned sugarcane fields. Burning sugarcane before the harvest is hence an important factor for the economic viability of the farming operation. During the policy forum, participants out-lined that innovative companies are introducing alternative harvesting practices which do not require pre-harvest burning. To what extent this has already reduced this concern could not be confirmed.

Burning could also take place during the land development phase for oil palm cultivation, which has been mentioned as a major sustainability concern related to the palm oil sector in other countries, where expansion is taking place at a large scale and to some extent on fragile peat lands which can lead to peat and forest fires. For Thailand, no evidence exists that this is happening systematically or on a large scale; however, reports of peat fires in a protected area in Phatthalung Province are indi-cating a relationship between increased agricultural activities by the local population (including for oil palm plantations) and the incidence of fires in protected areas45. Fire is not only an issue related to air quality but can also have significant environmental impacts, and the impacts of fire from agricul-tural activities is reported as a challenge in protecting the natural forest ecosystems in Thailand46.

Air pollution from smoke and dust during transport, storage and processing is another potential im-pact of biofuel production, which was raised as a concern during the stakeholder interviews. In par-ticular where biomass is burnt for electricity generation, air pollution can be severe if no adequate measures are taken in such power plants. The same applies to the storage and transport of biomass before it is fed into the processing plant. Local communities report that exposure to large amounts of dust from such biomass can be a negative side effect of bioenergy facilities. However, the main source of electricity from biomass in Thailand is produced from bagasse and air pollution from burning bagasse in large, integrated sugar processing facilities is not a major concern, as concluded during the policy forum.

44

Bangkok Post February (2013) and Morgera et al. (2009). 45

Thiwatsirikul K. et al. (2012). 46

ICEM 2003.

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Greenhouse gas (GHG) emissions Several studies assessing the GHG emissions of biofuels have been conducted for the Thai context47. They conclude that there is a high potential to reduce emissions by replacing fossil fuels with ethanol and biodiesel48. The extent to which a reduction in GHG emissions can be achieved depends very much on the practices applied. Land use change and the conversion of high carbon land, such as nat-ural forests, to agricultural crops used for biofuel production have the largest negative impact on the GHG balance. In Thailand, as most available land is already used for agriculture and the remaining forests are legally protected, further area expansion for increased feedstock production is expected to take place mainly on agricultural and waste land, thus avoiding forests49. For the expansion of cassa-va production in particular, no evidence has been found that such expansion takes place on high car-bon soils in Thailand and increased production is expected to mainly result from improved yields50.51

Research on the implementation of the E10 policy goal of 2012 concludes that this policy leads to significant emission reductions.52 If land use change is taken into account, the potential to reduce GHG emissions is expected to be lower than in the calculations provided and only to be present under certain scenarios – as changes in soil carbon due to the clearing of land would contribute to increased carbon emissions.53 Where fossil fuels are employed in the refining process of ethanol plants, the refining process becomes a major contributor to the overall GHG emissions due to the high energy demand in ethanol refining54.

For ethanol produced from cassava in particular, the GHG reduction potential, assuming that no land use conversion takes place, is estimated at more than sixty percent (60%).55 The potential to reduce GHG emissions by using ethanol from sugarcane is estimated at between fifty (50%) and eighty per-cent (80%). To what extent emissions can be reduced, largely depends on the reduction, or the con-trol of burning of cane trash, and on the utilization of steam in the processing plant.56

For biodiesel, the overall GHG balance would also strongly depend on the land use change in the cultivation process. The next biggest contributor to emissions is the wastewater in the palm oil mills, which in some cases is stored in open ponds and emits methane. Where methane capture is applied to produce electricity from biogas, the overall emissions can be reduced significantly. Different sce-narios have been calculated in an unpublished study concluding that the common practices applied in the Thai biodiesel production lead to significant reductions in GHG emissions compared with con-ventional diesel.57

Although no specific research on the GHG balance of electricity generation from bioenergy has been considered, data from the Thailand Greenhouse Gas Management Organization (TGO) points to the fact that a lot of bioenergy projects are being developed as projects under the Carbon Development Mechanism (CDM). They hence are expected to lead to emission reductions. TGO approved 221 CDM projects of which twenty-two percent (22%) are related to biomass and fifty-six percent (56%) to biogas. Those two sectors play an important role in the expected overall emission reductions from

47

Gheewala et al. (2011), Silalertruksa et al. (2009), Amatayakul and Berndes (2007), Damen and Salvatore (2010) and Kaewmai et al. (2012). 48

Damen and Salvatore (2010) 49

Amatayakul and Berndes (2007). 50

Damen and Salvatore (2010) 51

Silalertruksa et al. (2009). 52

Amatayakul and Berndes (2007). 53

Silalertruksa et al. (2009). 54

Damen (2012). 55

Elbehri et al. (2013). 56

Gheewala et al. (2011). 57

Keawmai et al. (2012).

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CDM projects in Thailand, which currently (2012) add up to 12.71 MT CO2e/year.58 Thai CDM pro-jects are also subject to a number of further sustainability criteria, covering natural resource, envi-ronmental, economic, technological and social issues.59

Conservation The main risks associated with biofuel production on conservation values and important ecosystem services arise from the expansion of agricultural production areas into natural or otherwise more sustainably managed landscapes. Thai biofuel producers depend to a large extent on small-scale farmers to provide them with the necessary feedstock for further processing. Large-scale expansion of agricultural land by single companies for biofuel production is not expected to take place according to recent research and considering the limited availability of unoccupied land. As Barney states, refer-ring to the forest plantation sector, latest developments “indicate that the allocation of large-scale concessions to plantation companies in Thailand is now nearly impossible”60.

However, the increased demand for agricultural feedstocks from the biofuels market puts pressure on natural landscapes. This is a concern in Thailand where encroachment into protected areas is regu-larly reported, sometimes with devastating impacts on locally important protected areas. The media is holding local communities as well as local and foreign investors responsible.61 This shows that, despite limited large-scale conversion of forest or natural landscapes for agricultural use, severe im-pacts on national landscapes can result from the cumulative encroachment on small areas by a large number of small-scale farmers.

Considering this problem of protected area encroachment and the general pressure on land for agri-cultural production, the maintenance of buffer zones, as required by the RSB Standard, is unlikely to be practiced on privately owned land. Farmers with limited access to land may be particularly reluc-tant to maintain buffer zones where their farms are located close to areas with important conserva-tion values. Where buffer zones are part of protected areas, projects have shown that community participation in managing those buffer zones can be an effective tool in maintaining them. The recog-nition of buffer zones outside of the protected areas is however considered to be weak and often local communities are not aware of the boundaries of protected areas.62

2.2 Social issues

Rural and local development Poverty in Thailand has been reduced significantly over the last decades. It still persists, mainly in agricultural households that are dependent on rice cultivation as their only source of income. With an estimated GDP per capita of USD 10,000, 8.1% of the population is estimated to live below the pov-erty line. Inequality in the country is high and Thailand ranks twelfth in the list of countries with the highest Gini index63. Thailand has one of the lowest official rates of unemployment in the world and its economy depends on the influx of cheap labor from neighboring countries. Making up approxi-mately ten percent (10%) of the total workforce, about 2.5 million migrant workers are employed in Thailand of which around eighty percent (80%) come from Myanmar.64

58

TGO. 59

Morgera (2009). 60

Barney (2004). 61

Pongrai (2012), Sarnsamak (2011) and Sarnsamak (2011a). 62

ICEM (2003). 63

This index measures the degree of inequality in the distribution of family income in a country. 64

Wallace (2013) and CIA (2013).

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Whether poor households could benefit from increased feedstock demand for bioenergy production and possibly higher prices for agricultural products will depend on how they will be able to adapt their cropping systems and how increased farm incomes will be distributed between land owners, tenants and farm workers. In the event that bioenergy demand leads to increased food prices, those farmers who cannot benefit from increased prices for their production would certainly be worse off. In the paragraph on food security below, the impacts of the Thai bioenergy development on food security and prices is discussed in more detail.

The contribution to rural development is often used as an argument to promote bioenergy produc-tion. However, general concerns have been raised during the interviews about equal and fair profit sharing along the supply chain of agricultural based products, between small-scale farmers and trad-ers or processors. Limited research is available on the impacts of bioenergy production on rural de-velopment and the topic was not discussed during the policy forum.

A study on the impacts of a biorefinery complex on rural economic development did not result in clear conclusions. Whereas the Human Development Index (HDI) of farmers supplying the biorefin-ery is lower than the regional average, it could still be higher than the national average of the farming population, as their HDI is overall lower than the overall national average. Wages and profits of the farmers supplying feedstock to the biorefinery complex comprised the largest share of the total pro-duction cost. Employees of the biorefinery complex had a higher HDI than the regional average.65 The study also sees positive impacts as a result of the contract farming model implemented in sugarcane production in Thailand, which provides the farmers with a secure market and a stable income. The share in returns from revenues from the sugar industry is set at seventy percent (70%) for sugarcane planters and thirty percent (30%) for sugar processors, which is prescribed in the Cane and Sugar Act (1984)66.

The contract farming agreements that are common in the Thai sugarcane industry, however, are not seen as beneficial by everyone and economic risks are mentioned due to the necessary and high in-vestments for which farmers usually depend on loans from the sugar factories. If the prices and yields promised to farmers and proclaimed to persuade farmers to investment do not materialize, farmers may enter a debt cycle which could eventually even result in them losing their land.67 Further re-search and consultation would be required to provide a clear assessment of the benefits of increased demand for sugarcane and how this and the contract farming arrangements in Thailand impact on local development.

The Southern Region of Thailand shows a success story in terms of rural development in the main palm oil producing provinces. The positive development over the last fifty years can be attributed to access to land for rural communities and the cultivation of rubber and palm oil. The trend towards small-scale farmers rapidly expanding oil palm plantations in other regions of Thailand, is proof of the economic attractiveness of the crop to small-scale farmers. Considering that establishing oil palm plantations requires relatively high investments, it would be worth exploring whether the least equipped farmers could benefit from that trend.

Land rights Land rights in Thailand are a complex issue according to the responses received during interviews. Often laws on land rights leave room for interpretation and are interpreted differently by different government organizations. In relation to the Thai policy on bioenergy, land rights have not been mentioned as an issue of concern, as large-scale land acquisition for bioenergy projects is reportedly

65

Gheewala (2011). 66

Morgera et al. (2009). 67

AAN (2012).

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not taking place anymore. This topic also did not receive particular attention during the policy forum as stakeholders gave other topics a higher priority. Gaining insights into existing land disputes result-ing from land acquisition in the past, and ascertaining whether they are related to bioenergy produc-tion, would require further research.

It has however been demonstrated that land governance problems can lead to violent conflicts; for example, a recent land dispute case between a palm oil company and land reform beneficiaries led to the killing of community members. This also led to representatives from the community protesting at the Thai government house68. Further conflicts over land concessions that were given to companies in the past have arisen since those concessions expired, but companies are reluctant to give back the land. Furthermore, corporates are suspected of seizing hold of agricultural land from local communi-ties using dubious practices such as making false promises in contract farming agreements, which could result in high debts and the farmers eventually losing their land69. Such cases have been linked to the sugar as well as the pulp and paper industries70.

On the other hand, farmers are reported to occupy private or government owned land. The most common land conflicts in Thailand are reported to occur between state agencies and local people: a problem that is partly due to the fact that large areas considered as forest land were demarcated after they had been settled on by farmers71. A land reallocation project which aimed to hand over state land to landless farmers for the cultivation of biofuel crops, could not be implemented due to concerns over land conflicts with local communities.72 Communities are in a position to express their concerns related to land use and that their concerns are considered in government decision making.

Human and labor rights Human and labor rights in bioenergy production were not a major concern of the interviewed stake-holders and were not raised as an issue during the policy forum. Labor standards in processing plants are rather good (as described above) and exploitative practices are usually associated with other in-dustries (mainly the fisheries and garment sectors). Although agricultural production largely depends on small-scale farmers, those farmers often use external labor. Labor rights in the informal agricul-tural sector are difficult to monitor and could lead to the abuse of labor or human rights, which would not be compliant with the RSB sustainability requirements.

Of particular concern is that minimum wages in Thailand do not apply to the agricultural sector and their overall regulation is very limited. The implementation of international labor standards on small-scale farms – for example health and safety related provisions – are hardly, if at all, monitored and deserve further attention. Potential concerns and approaches for improvement would not be limited to the bioenergy sector, but would require a broader approach. The stakeholders interviewed expect that due to the limited availability of farm labor, relatively good working conditions could be present on small-scale farms.

This contrasts with the assessment of the International Labour Organization (ILO), which reports that, in general, underpaid migrant workers with no access to adequate living conditions are a point of concern in Thailand73. A large number of migrant workers are entering Thailand to work in the agricultural sector, hoping for better opportunities than in their home countries. Although it is as-sumed that a large proportion of migrant workers do not encounter any violations of their human

68

Globalvoices (w.y.). 69

Lang (2003). 70

Barney (2004). 71

Barney (2004). 72

Global Researcher (2011). 73

ILO (2008).

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rights in Thailand, human rights and labor rights abuses have been reported in the food processing industry, the garment sector and in particular in the in fisheries sector.74 Migrant workers could face low wages and discrimination in relation to wages, unsafe and unsanitary workplace conditions, a lack of access to health care, and there are reports from certain sectors that work relationships could be considered as semi-forced labor.75 For bioenergy production, no particular concerns could be found.

Food security Thailand is currently a globally leading exporter of rice, sugar and cassava. The vast majority of agri-cultural land in Thailand is used for rice cultivation. Thailand also exports a significant share of its palm oil production (exporting on average 15-20% of its total production over the last five years). The anticipated impacts of the Thai bioenergy policy on food prices and food security have been discussed in a number of studies76. Overall, concerns about any negative impacts of the Thai bioenergy industry on food security at the national level remain relatively low, but uncertain. Interviewed stakeholders did not perceive food security as a major sustainability concern in Thailand arguing that the availabil-ity of feedstock within Thailand and the region is high. However, participants of the policy forum mentioned the importance of monitoring the competition between feedstock for bioenergy and for food use which could potentially arise in the future.

Salvatore and Damen expect rising prices of crops used as biofuel feedstock as a result of the imple-mentation of the AEDP (2008-2022)77. They calculate different scenarios to assess the impacts of rising food prices and conclude that under most scenarios rising prices have negative impacts on poor households, especially rice farmers who do not diversify to other crops. They however acknowledge that a large number of factors could influence the impact of an increased demand for bioenergy on agricultural commodity prices and food security. Positive as well as negative outcomes are possible depending on those factors. One important factor will be the ability of rural households to adapt to the changing market conditions which result from bioenergy promotion in Thailand.

Regarding ethanol production, rising prices for feedstocks like cassava and sugarcane are expected to lead to productivity gains as well as an expansion of the cultivated area. Currently, cassava yields are far below their potential and could be doubled relatively quickly by applying better production tech-nology. This would reduce the pressure on food security. Area expansion has mainly been taking place on land previously used for maize (in the eastern region) and rice (in the north-eastern region) cultivation and this is expected to continue to meet the feedstock demands resulting from the AEDP78.79 Maize production has been declining over the last decade and is being substituted by im-ports from neighboring countries, such as Laos and Cambodia. Considering the current price ad-vantages of producing ethanol from molasses, the increasing targets for ethanol production will likely lead to higher demand for molasses. However, this would not affect food security, as molasses is mainly used for the production of liquor. The use of sugar juice for ethanol production is prohibited in Thailand with one exception being where sugarcane is grown on contaminated land.

The amount of the relevant crops available from domestic production will strongly depend on devel-opments in the export markets, technology developments and government regulations towards ex-port of certain feedstocks. If the declining area used for rice production cannot be compensated for

74

Vartiala et al. (2013). 75

Archavanitkul and Hall (2011). 76

Prasertsri and Kunasirirat (2009), Amatayakul and Berndes (2007), Silalertruksa et al. (2012), Eisentraut (2010) and Damen and Salvatore (2010). 77

The plan has been revised in 2012 78

Damen and Salvatore (2010). 79

Amatayakul and Berndes (2007).

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with increased yields, less rice will be available for the export market. Whether Thai communities can benefit from this trend will depend on a number of economic factors as well as the agricultural policy measures of the Thai government. Currently, price guarantees for rice have led to prices above the world market price, which has resulted in a sharp reduction of exports over the past two years and has also led to large stocks of rice being held by the Thai government.

Palm oil stocks are closely monitored by the Thai government and prices of cooking oil are controlled. The mandatory blending quota for biodiesel is adjusted depending on palm oil production to avoid shortages and price hikes for cooking oil. The necessary expansion to meet the significantly increas-ing demand based on the AEDP has the potential to positively impact rural development in the north-eastern region of Thailand80. Whether it could lead to the replacement of other food crops and how this could affect food security deserves further attention.81 In previous cases, the Thai government reacted to a shortage in palm oil supply by adjusting the biodiesel blending quota and allowing palm oil imports to ensure the affordable availability of cooking oil for consumers82. Currently (2013), palm oil stocks in Thailand are high and world market prices are depressed. Large stocks of palm oil have been accumulated in Thailand and the sector is discussing the possibility of using palm oil directly in power plants, thus replacing imported fuel oil.

80

Damen and Salvatore (2010). 81

Amatayakul and Berndes (2007), Prasertsri and Kunsirirat (2009). 82

GBIN (2010).

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3. Thai regulations related to the sustainabil-ity impacts of bioenergy

The overall goal and justification of the promotion of bioenergy in Thailand underlines the im-portance of becoming less dependent on imported fossil fuels and being prepared for a future of ris-ing fossil fuel prices. At the same time, reducing greenhouse gas emissions and supporting green growth is explicitly mentioned in the AEDP (2012-2021). Food security is another concern which is considered in the Thai policy on biofuels, which states that biofuel development should not threaten the availability of food. Moreover, bioenergy is seen as a powerful tool to promote investments in rural areas and provide livelihoods to farming communities.

The sustainable management of natural resources is covered in several articles of the Thai Constitu-tion and a large number of laws and regulations on the management of forests and natural resources exist. Those regulations, as well as the responsibilities of different government institutions, often overlap. This chapter describes the regulations that are in place to ensure that negative environmen-tal and social impacts are minimized, even though these regulations do not specifically address the Thai bioenergy sector but apply more generally. These regulations are generally mentioned by gov-ernment institutions when questioned for sustainability safeguards concerning the bioenergy policy of Thailand. Table 6 gives an overview of each priority issue of the RSB framework in relation to the existing regulations and an assessment regarding the strength and level of enforcement of the exist-ing regulations in Thailand. The assessment is based on secondary research as well as on the findings from the policy forum. Further elaboration on each priority issue and related sources of information are given in the sections below.

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Table 6: Regulations and their enforcement to address priority sustainability issues Priority Is-sue

Related Regulations Strength of regulation

Level of en-forcement

Conservation Forest Act (1941) National Park Act (1961) National Forest Reserve Act (1964) National Forestry Policy (1985) Cabinet Resolution 23/3532 / Logging Ban

(1989) Wild Animal Preservation and Protection Act

(1992) Forest Plantation Act (1992) Thai Forestry Sector Master Plan (1993) Community Forest Bill (2007)/voided 10th National Economic and Social Develop-

ment Plan

+ -

Water and Air (processing)

Factory Act (1969/1992) Enhancement and Conservation of Natural

Environmental Quality Act (1992) Hazardous Substances Act (1992) Public Health Act (1992) National Health Act (2007)

+ 0

Water, Air and Soil (agricul-ture)

Land Development Act (1983) Hazardous Substances Act (1992)

0 -

Farm Workers’ Rights

Thailand Labor Protection Act (1998/2008) Labor Relations Act (1975) Occupational Safety, Health and Environment

Act (2011)

- -

Land Rights Land Code (1954) Land Code Promulgation Act (1954) Land Reform Act (1975) National Land Policy (1987) Resolution of State Land Encroachment (1992)

+ 0

Food Security Mentioned in the AEDP Food Security Strategic Framework (2013-

2016) Revised Agricultural Zoning / Agricultural

Economics Act (1979)

0 0

Local Participa-tion

Tambon Council and Administrative Authority Act (1994)

Decentralization Act (1999) Thai Constitution (2007)

0 -

+ ~ strong regulations / enforcement 0 ~ medium level of regulation / enforcement - ~ lack of regulation / challenges in implementation

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3.1 Considering environmental impacts

The environmental legislation in Thailand is based on the Enhancement and Conservation of Natural Environmental Quality Act (1992), which also calls for the National Environmental Board to coordi-nate the different concerned ministries. Environmental Impact Assessment (EIA) guidelines in Thai-land as well as the related environmental legislation are elaborate and well formulated by authorities.

The requirements for EIAs are prescribed under the Enhancement and Conservation of Natural Envi-ronmental Quality Act. An EIA has to be conducted for bioenergy projects with a capacity of 10 MW or more per year, according to stakeholder interviews. Participants of the policy forum mentioned that the requirement to conduct an Environmental and Safety Assessment (ESA) for projects with a capacity of between 5 and 10 MW has been recently introduced. It however could not be concluded what the ESA entails and which government organization is responsible for its implementation and enforcement. Building a sugar mill or a refinery also requires an EIA. The EIA needs to be conducted by an external consultant registered with the Office of Natural Resource and Environmental Policy and Planning (ONEP) under the Ministry of Natural Resources and Environment (MONRE), and the EIA report requires approval by ONEP. ONEP also sets certain procedures to be followed when con-ducting an EIA.83

Bioenergy related industrial standards are outlined in the National Environmental Quality Act. This includes emissions standards, standards for wastewater effluent and wastewater in biogas plants. The Factory Act, the Hazardous Substances Act as well as the Public Health Act are also relevant in regu-lating wastewater in industrial facilities. The Hazardous Substances Acts also covers air pollution and emissions.84

The answers to the interviews conducted concerning the implementation of the environmental regu-lations in practice were ambiguous, generally stating that Thai environmental regulations are well implemented but that shortcomings in capacity and the integrity of responsible staff can be a chal-lenge. The discussions during the policy forum confirmed this statement; however, suggestions have been made to improve the EIA requirements for bioenergy projects by also covering smaller projects, as they could have significant environmental and social impacts if local participation is not included in the project development process.

The main concerns related to the impacts of biomass based power plants have been raised (see 2.1). Secondary research points to shortcomings in participation and public consultation during the EIA process, the need for an independent body to review EIA reports as well as measures to control the quality of the EIA auditors’ work.85 The EIA procedure has also been criticized as giving insufficient power to authorities to screen projects and for being focused on the paper work process which typi-cally results in approvals after amendments to the EIA reports are made – rather than halting pro-jects that will be environmentally harmful. The procedure also puts time pressure on the review committee, which is often already constrained by limited resources. The process also allows standard assessments for similar projects (time, size, activity or location of project), disregarding the fact that environmental impacts should always be considered for each individual project and that environmen-tal impacts are cumulative. This reportedly reduces the effectiveness of the EIA process in Thailand.86

The National Health Act (2007) gives Thai people the “right to live in the healthy environment and environmental conditions” (Section 5). It also postulates the responsibility of state authorities to

83

ONEP (2012). 84

Morgera et al. (2009). 85

Chesoh (2012). 86

Kititasnasorchai and Tasneeyanond (2000).

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provide relevant information and outlines the rights of affected communities to request an assess-ment of health impacts from any public policy body as well as detailing the right to participate in such an assessment. The Act also calls for the establishment of the National Health Commission (NHC) which has the duty, among other things, to “prescribe rules and procedure on monitoring and eval-uation in respect of national health system and the impact on health resulting from public policies, both in the level of policy making and implementation” (Section 25(5)).87 Through its constituencies, the NHC provides a strong foundation for public participation on health policies.

Although a Health Impact Assessment (HIA) can be demanded by communities, they have reportedly never led to the cancelation of a project. The usual response to a HIA is the request for further mitiga-tion measures for potential health impacts. Implementing those measures and monitoring their im-pacts requires expertise and resources which the Thai authorities often lack, according to concerned Civil Society Organizations (CSOs).88

Conservation The Wildlife Conservation Society describes Thailand’s protected areas network “… [as] one of the strongest systems in South East Asia”89. The Department of National Parks, Wildlife and Plant Con-servation under MONRE regulates protected area management, but a number of other ministries are also directly or indirectly responsible for protected area planning and management, such as the MoAC, the Office of the Prime Minister and the Ministry of Interior.

A number of protected area categories exist in Thailand – including national parks, forest parks, wildlife sanctuaries, community forests and coastal and marine reserves. Important wetlands have also been recently included into the categories of protected areas. Twenty-five percent (25%) of Thai-land’s land area is targeted for inclusion in the protected area system. This goal has reportedly been met.90 Overall, biodiversity and forest conservation are the main basis for protected area demarca-tion. Although management plans exist for most protected areas, their implementation varies greatly on the ground and has not always been effective. Encroachment by economic activities like agricul-ture, real estate development and tourism is a challenge.91

Logging has been banned nationwide in Thailand since 1989 and the remaining forty percent (40%) of forest cover is protected through the National Forestry Policy (1985) targeting twenty-fiver percent (25%) conservation forest and fifteen percent (15%) commercial forest. Those figures were based on the objective of protecting important watersheds as well as meeting the timber requirements for Thailand. All land with slopes of more than a 35% incline is considered as forest land under the Na-tional Forest Policy. Most of Thailand’s forests are within protected areas and the regeneration of degraded areas has been increasingly successful with reforestation also taking place outside of pro-tected areas. Considering that less than forty percent (40%) of forest cover is left in Thailand, the status of the remaining forest area of forty percent (40%) needed revision. The 10th National and Economic Development Plan currently calls for maintaining a forest area of thirty-three percent (33%) of which at least eighteen percent (18%) is conservation forest. The Community Forest Bill of 2007 provides legal rights to communities relying on their forests for managing the natural re-sources.92 The process of declaring or expanding protected areas as well as the management of those areas in a number of cases led to conflicts with local communities or indigenous people. Local com-munities are increasingly being involved in protected area expansion and management. A number of

87

National Health Act (2007). 88

EARTH et al. (2012). 89

WCS (w.y.). 90

Woods et al. (2011). 91

ICEM (2003). 92

Morgera et al. (2009).

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pilot projects on community involvement in the management of protected areas were initiated in 2001 by the Royal Forest Department.93

Challenges in implementing the regulatory framework for environmental conservation and forest protection remain, considering the reports of encroachment into protected areas for agricultural or property development. However, measures are taken to address negative environmental impacts caused by bioenergy projects. One example is the recent temporary closure of an ethanol plant due to inacceptable practices regarding the treatment of wastewater94. Currently efforts are being made to strengthen the investigation of such encroachment and violations of conservation laws. To achieve this, geo information technology is used by the Department of Special Investigation (DSI) for moni-toring95.

3.2 Considering social impacts

Labor and Human Rights Thailand is a member of the United Nations Human Rights Council and a signatory state to various major international human rights treaties, which obliges the government to respect the human rights of all people and provide adequate social services. In addition, Thailand ratified fifteen ILO Conven-tions - among those are five ILO Conventions covering issues like child labor, forced labor and equal wages. Thailand has not ratified ILO Conventions 81 and 129 on labor inspections in industrial work-places and agriculture respectively.

The 1998 Labor Protection Act is the legal basis for important labor regulations like minimum wages, maximum work hours, child labor, occupational health and safety as well as the prosecution of labor right abuses. This Act is generally in line with internationally accepted standards and the rights cov-ered in the Labor Protection Act apply equally to migrant and Thai labor. However, agricultural labor is exempted from the regulations on minimum wages, maximum working hours and maternity leave96. The Department of Labor Protection and Welfare (DLPW) is responsible for promoting the implementation of labor rights.97

It is questionable whether the protection of labor rights is monitored and ensured, especially in the small-scale agricultural production sector. A report by the ILO in 2008 stated that more than thirty-five percent (35%) of the workforce in the cassava sector receives less than the minimum wage. It is however not clear which minimum wage the ILO was referring to, as the agricultural sector is not covered by a minimum wage in Thailand. Law enforcement on child labor has been considered equal-ly weak by the ILO in a report from 2008. 98 According to the United States Department for Labor however, since then Thailand made significant advancements in eliminating child labor99.

The protection of migrant laborers is considered insufficient, as no specific measures have been taken to ensure the protection of their rights100. Enforcing rights in the Thai justice system is a difficult process, especially for migrant workers. The Thai National Human Rights Commission as well as civil society and human rights activist networks in Thailand, do however provide support.

93

ICEM (2003). 94

Sapp (2013). 95

Kunakornpaiboonsiri (2012). 96

ILO (2011). 97

Archavanitkul and Hall (2011). 98

Elbehri (2013). 99

US DOL (2012). 100

Archavanitkul and Hall (2011).

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In its 2008 report, the ILO however, also points out improvements in equal pay as well as social secu-rity101 and examples do exist where local communities effectively used national regulations to enforce their rights.102

Land Rights The legal framework for land rights in Thailand is complex. Responsibilities are given to various gov-ernment agencies and are often overlapping. Government agencies that are involved in the land ti-tling process are the Department of Land under the Ministry of Interior, the Royal Forestry Depart-ment under the Ministry of Natural Resource and the Environment, the Royal Forestry Department, the Ministry of Finance as well as the Ministry of Agriculture and Cooperatives103. A large number of land use right deeds exist, which were prescribed by the Thai Land Code of 1954. However, some land use rights are based on other legal documents e.g. land rights related to land reforms or the Commu-nity Forest Bill of 2007. Currently, around forty percent (40%) of land in Thailand is considered pri-vate land. The only land title deed providing full, private ownership of the land is called a “Chanot”. In 1975 the Land Reform Act was put in place to address the concern of land concentration and land-lessness of the rural population.

Governance of land tenure in Thailand is considered to be one of the best in the region, although constraints remain, often leading to land conflicts between local communities and the state authori-ties. The Public Land Encroachment Committee (PLEC) was established to address those conflicts. Regional offices are in place to monitor encroachment on public land and coordinate the work of different responsible agencies like the Royal Forest Department (MoAC), the Agricultural Land Re-form Office (MoAC) and the Department of National Parks (MoNRE). Affected communities or indi-viduals often address the Thai National Commission on Human Rights with their complaints as the capacity of the PLEC is limited and they have to deal with a large number of accumulating cases.104

Agricultural development planning To regulate the production of the six major agricultural crops in the country, a crop zoning initiative is used by the MoAC. The zoning is coordinated by the Land Development Department (LDD). With-in the zoning, suitable areas for the six major agricultural crops are defined and delineated. The zon-ing takes into account land suitability and availability, and the increasing feedstock demand for bio-energy production is considered in setting agricultural production goals. Ten million rai are delineat-ed for palm oil production in Thailand. The effective implementation of the zoning has not been dis-cussed in detail, but officers of the MoAC state that government support programs, like buying schemes and price subsidies, will be limited to farmers who manage their lands in accordance with the zoning105.

Although crop specific development objectives are formulated in plans by the MoAC, clear strategies on how to achieve those objectives are often lacking and in some cases government plans fall behind the actual development on the ground and are revised according to updated production figures. By implementing the zoning, the Thai government hopes to better influence agricultural development in the country which is based on the decisions and practices of a large number of small-scale farmers.

The challenge of supporting a large number of small-scale farmers was mentioned as a major hurdle in promoting sustainable agricultural development during the policy forum. While some stakeholders would argue that government budgets do not allow sufficient investment in capacity building of

101

ILO (2008). 102

Doksone (2013). 103

Samranjit (w.y.). 104

Nabangchang and Srisawalak (2008). 105

OBG (2013).

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farmers, others argue that funds are often not used efficiently or are not targeted at the right inter-ventions. The price pledging schemes used by the current government have been criticized, in partic-ular, of consuming large government budgets but at the same time not being effective in addressing the challenges of agricultural development in Thailand.

3.3 Regional approaches

A number of regional initiatives on sustainable bioenergy have been established over the last years. Some of them will be briefly described below.

ERIA working group on sustainability assessment methodology The Economic Research Institute of ASEAN and East Asia (ERIA) was established during the third East Asia Summit which took place in November 2007. The establishment of the ERIA was supported by all represented leaders from the respective East Asian countries. The ERIA acts as an independent research institute to provide policy advice based on scientific research in its three main areas of work: (1) deepening economic integration, (2) narrowing development gaps, and (3) sustainable develop-ment.

In 2007, the expert working group on “Sustainability Assessment of Biomass Utilization in East Asia” was established under the ERIA. The working group aims at providing a methodology for evaluating the sustainability of biomass utilization in East Asia and consists of ten members from Japan, Malay-sia, Thailand, Philippines, Indonesia and India. The methodology covers environmental, economic and social impacts. After a first methodology was developed in 2009, it was field tested in four pilot projects in 2009 and 2010. The results of the field tests have been integrated into the revised meth-odology and a further extension of the methodology took place in 2011 and 2012. The methodology aims to serve as a tool for decision makers on comparing the sustainability of different bioenergy options and whether to implement certain bioenergy initiatives.106 Currently the research on the methodology has been concluded and was handed back to the policy makers. It is not yet clear how this will be taken up at the policy level.

Biofuels database project in East Asian countries The objective of the biofuels database project is to collect information on the current biofuel situation and related policies in East Asian countries. This information will be collected and disseminated through a website which also acts as a platform to share good practices on biofuel project establish-ment.107 Currently only three projects from Japan are available on the website and it does not seem to be actively maintained108.

APEC Biofuels Task Force The APEC Biofuels Task Force was established during the Seventh Meeting of APEC Energy Minis-ters in 2005 to provide a balanced approach towards fuel security in the region. Since then, the task force has been working on assessing the economics of biofuels as well as biomass availability in APEC countries and developing guidelines for a biodiesel standard. During the Eighth Meeting of APEC Energy Ministers in 2007 it was concluded that biofuels from a number of different feedstocks are cost competitive and could replace fossil fuels to a significant degree in the region. After this meeting, the working group supported a number of projects on feedstock resources, trader potential, econom-ics and technology of feedstocks, biomass resource elasticity and employment opportunities. A survey in 2008 concluded that biofuels have the potential to replace one fifth of crude oil imports in the

106

Shabbir (2012). 107

Marasigan (2011). 108

New Energy Foundation.

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region. In 2010, a study on Sustainable Biofuel Development Practices was finalized, giving consider-

ation to multi-stakeholder initiatives like the GBEP, RSB and RSPO109. In the same year, a workshop on the topic was organized during the Sixth APEC Biofuels Task Force meeting, concluding that:

boosting the yield of biofuel feedstocks is crucial to reduce the land requirements of biofuels; land use regulation plays an important role in ensuring the sustainable development of bio-

fuels; and research and development is necessary to encourage the establishment of second generation

biofuels.

The Task Force work ended in 2011 and any further necessary research falls under the auspices of the

of the APEC Expert Group on New and Renewable Energy Technologies.110

GMS Core Agriculture Support Program Phase II: Pillar 3 Bioenergy and Biomass management The Core Agriculture Support Program (CASP) of the Greater Mekong Subregion (GMS) includes a pillar on bioenergy. Under this pillar, the CASP is “promoting agriculture as a leader in providing clean renewable energy and cross-border eco-friendly supply chains”. This currently covers:

The regional standard and regulatory framework for biomass and bioenergy; Biomass management for bioenergy and food security; and Foreign Direct Investment in eco-friendly supply chains.

The budget for technical assistance in this pillar is four million Dollars (USD 4 million), to be imple-mented between 2011 and 2014. Under the current program, a roadmap for the regional standard development has been established and pilot projects have started.

109

Kunen and Chalmers (2010). 110

APEC (2012).

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4. Recommendations

This section makes recommendations on possible amendments to the regulatory framework and its implementation. The recommendations are based on the assessment of the main sustainability issues related to bioenergy production and the regulations in place to address those issues. The aim is to ensure that the Thai policy on bioenergy will prevent undesirable negative impacts on humans and nature. The RSB framework is applied to the Thai context as a reference for sustainability.

4.1 Environmental safeguards

Conservation The research has shown that while the necessary regulatory framework to protect forests and biodi-versity is adequate, implementation is unsatisfactory. Policy recommendations to address the main challenges in implementing the regulations on forest and biodiversity conservation are detailed in the following paragraphs.

More clarity and agreement on the classification of land is needed between different government agencies within the MoAC, MoF and MoNRE. Current conflicting land classifications need to be aligned to develop a single database and related maps outlining the land classification of the country. The recently introduced Department of Special Investigation (DSI ) Map could be a good starting point in this regard111. Where conflicting interests in land classification exist and adjustments of the current land classifications could impact local communities, participatory procedures for solving those conflicts need to be established. An approach which supports the development of local solu-tions based on the participation of stakeholders is favored over a centralized, top-down approach. Compensation schemes for local communities as well as options for involving communities in the sustainable management of protected areas should be considered.

Issuing secure land titles to farmers will generate incentives for long-term investment in their farm-land instead of conducting livelihood activities for short-term economic gain. This could reduce ex-ternalities like encroachment on protected areas as a result of development or speculation. A one-stop service for land titling with clear and transparent procedures is needed to ensure that equal access to secure land titles can be provided for all groups in society. Implementation of the land re-form program should be advanced but depends on clarity and consensus regarding land classification and existing land rights.

Strengthening the capacities of the local authorities responsible for the management and monitoring of protected areas (like national park staff) is an important pre-condition for effective enforcement. Reports clearly indicate that efforts are underway and budgets are available to tackle the challenge of enforcement on the ground112. It is important to monitor the boundaries of protected areas and im-plement sanctions where the boundaries are violated and where illegal land encroachment occurs. However, awareness-raising on the presence of protected areas and the importance of their conserva-tion could provide equally good results.

Water and air (processing) The assessment has shown that Thai regulations on pollution control are elaborate and adequate to a large extent. However, there are challenges with respect to their monitoring and enforcement as out-lined in chapter 3. Clarifying the responsibilities of the different government authorities and their

111

Sarnsamak (2012). 112

Pramotmaneerat (2013).

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respective expectations towards operations would make implementation and enforcement more ef-fective. Stepping-up resources in relevant departments of the MoNRE like the Pollution Control De-partment or the Department of Industrial Works (Ministry of Industries) is an important measure to ensure that bioenergy related processing facilities can be regularly monitored. Alleged misconduct by government officials is reported to be an important factor inhibiting the adequate implementation of environmental regulations in Thailand. Putting in place a system to monitor the practice of local inspectors which would hold them responsible, is crucial to avoid malpractice and abuse of power.

Furthermore, the Thai government should promote research on advanced technologies for efficient waste management and pollution control to be used in bioenergy feedstock production and bioenergy generation. Advanced practices that go beyond legal compliance are already being implemented by some progressive companies, as discussed during the policy forum. Further uptake of those practices should be promoted and incentivized, for example with an adjusted adder rate for electricity pro-duced in operations with high environmental standards. This could also include incentives for reduc-ing the GHG emissions along the bioenergy production process.

This study shows that community rights as detailed in the National Health Act (2007) are often not sufficiently respected during the planning and operation of bioenergy projects. It is therefore recom-mended that adequate procedures for local participation in the development process of bioenergy projects are elaborated and implemented from the beginning. Those procedures should be based upon the guidelines of free, prior and informed consent as required in the RSB sustainability stand-ards. Requiring proof that such procedures have been implemented, as a basis for obtaining the pow-er purchase permits, could be an effective tool to ensure that procedures are followed by both opera-tors and the responsible sub-district administrations.

In line with the RSB framework, effective Environmental Impact Assessments are important in defin-ing the requirements for sustainable production of bioenergy. Thailand has put regulations in place for EIAs. Their implementation is reported to provide increasingly positive results on avoiding envi-ronmental impacts of a wide range of projects for which an EIA is required. However, there is need for improving the EIA procedure and its implementation – for example with regards to public partic-ipation, as suggested in existing research113. It is recommended that EIAs are made compulsory for the bioenergy sector and also for biomass based power plants with a capacity below 10 MW because their impacts on local communities are currently not sufficiently addressed. As community owned projects could lack the resources to conduct an EIA, alternative approaches to EIAs should be consid-ered for those projects (e.g. simplified, community-based procedures).

Water, air and soil (agriculture) The assessment has shown that while the overall ambition of pursuing sustainable agricultural devel-opment is part of the National Social and Economic Development Plan of Thailand, the current regu-latory framework does not sufficiently address the mitigation of negative impacts on water, air and soil quality caused by agricultural practices. Effective policies should be put in place to promote good and environmentally friendly agricultural practices which allow farmers to increase productivity and to improve the soil health as well as the quality and availability of surface and ground water re-sources. To implement such policies, tools and structures for reaching out to large numbers of small-scale farmers in the Thai agricultural sector have to be taken into account.

A regulatory approach to promote good agricultural practices could incentivize the application of such practices on farms producing bioenergy feedstock. An example would be to replace current price guarantee schemes with direct payments for adhering to certain production practices. Policies aimed at more sustainable agricultural practices in Thailand have to be accompanied by capacity building

113

Chesoh (2011), Kititasnasorchai and Tasneeyanond (2000).

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and extension services for the large number of small-scale farmers which often lack organization. Supporting the organization of smallholders in cooperatives or other types of farmer organizations, and encouraging partnership models between farming communities and the private sector, could relieve government budgets and capacities in the long-term.

Research on sustainable agricultural practices and integrated pest management is an important pre-condition to make alternative technologies widely available in Thailand. Participants of the policy forum specifically called for research on the efficient use of biomass and the economic trade-offs for rural communities with regards to the use of bioenergy as a farm input instead of an energy source.

On the supply side, the liberal pesticide market in Thailand requires further regulation to discourage the use of hazardous chemicals. Current tax breaks for pesticide imports should be more selective and used to promote the trade in alternative, less hazardous formulas. The practices of input provid-ers require closer monitoring to ensure the legality and authenticity of farm inputs provided to farm-ing communities.

4.2 Social safeguards

Farm workers’ rights To ensure the welfare of the large number of workers in agricultural production, many of whom are migrants and women, the Labor Act and its provisions need to be extended to agricultural workers. Alternatively, a separate and specific regulatory framework could be developed, which should incor-porate the content of the numerous ILO Conventions that Thailand has committed to implement as well as additional ILO Conventions which are part of the RSB framework. Ratification of the Interna-tional Convention on the Protection of the Rights of All Migrant Workers and Members of their Families should be considered, as well as ILO Conventions 81, 87, 98 and 111. Provisions for agricul-tural workers should ensure the same labor rights for migrant workers as for Thai workers.

Actively promoting the development of agricultural workers’ representation could be effective in gaining insight into their working conditions, needs and concerns. Under the current conditions, monitoring of the employment practices in the informal agricultural sector has proven extremely difficult.

Enforcement of existing labor regulations in processing facilities and large agricultural operations should be improved by building the capacity and improving the integrity of the responsible imple-menting organizations like the Department of Labor Protection and Welfare under the Ministry of Labor and the provincial and district labor inspectors. Ratifying ILO Conventions 81 and 129 on labor inspections in industrial workplaces and agriculture would show Thailand’s commitment towards enforcement of labor rights.

Land rights To ensure that the land rights of local communities are respected during the implementation of bio-energy projects, as required by the RSB framework, clarification on the land classification in Thailand and alignment between different government authorities is needed. A commonly agreed upon trans-parent database and maps on land classification (see section on conservation) provide an important basis for effectively dealing with land titles and existing or potential land conflicts. Assessing and documenting formal and informal existing land use rights is an important basis for establishing a commonly accepted database. The potential for land conflicts resulting from bioenergy projects could be further reduced by resolving the current ambiguities of property rights in Thailand. Furthermore communities with customary land use rights should be provided with secure land titles by advancing the land titling and land reform process. Such improvements would provide clarity to bioenergy in-

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vestors on where investments for bioenergy development can take place with the lowest risk of dis-ruption from land conflicts.

The work of the Thai Human Rights Commission deserves further support as they play an important role as a focal point for communities whose land rights have been violated.

Developing and promoting good practices in contract farming and partnership models could help to balance the power in the relationship of private investors and farming communities and help avoid corporate land grabs through debt defaults of smallholders as described in chapter 2.

Feedstock supply for energy production and food security Considering the ambitious plans for bioenergy development in Thailand, effective policies need to be put in place to avoid potential negative impacts on food security, despite the fact that Thailand is not currently facing issues of food insecurity. Thailand recently introduced a new agricultural zoning system to better regulate the feedstock supply for energy as well as for food provision. It still remains to be seen how this approach will be implemented and how effective it will be.

There is a shortage of unused land suitable for sustainable agricultural development in Thailand. In order to meet the demand for bioenergy feedstock and to avoid competition with food production, the promotion of increased agricultural productivity is necessary. While research has shown that large advancements in agricultural productivity are possible for the three major crops currently used for bioenergy in Thailand (sugarcane, cassava and palm oil), the challenge is to transfer new technology to farmers and to encourage the implementation of good agricultural practices and new technologies at the farm level. Possible approaches to meet this challenge are mentioned in the section above on Water, Air and Soil (agriculture).

Furthermore, the impacts of promoting bioenergy under the AEDP on feedstock availability and commodity prices need to be continuously monitored. The bioenergy policy needs to provide suffi-cient flexibility to allow for adjustments if concerns about feedstock supply and food prices arise. Flexible admixture quotas, based on continuous stock and price monitoring should be favored over rigid targets. This requires close cooperation between the MoAC and the MoE. Special consideration in monitoring prices should be given to the impact of increasing food prices on poor households. This is important to ensure that the increased demand for feedstock by bioenergy projects does contribute to poverty reduction. The FAO is developing approaches to balance bioenergy use with food produc-tion and provides practical tools for policy makers114. Thailand should continue its cooperation with the FAO and apply those tools. Monitoring should include changes in agricultural land use which should be incorporated in an improved database on land use. The use of modern GIS technology could contribute to effective and efficient land use monitoring and add value to the current approach of local farm surveys and land use modeling.

Incentivizing certain types of agricultural practices could improve safeguards for food security. Ex-amples are agroforestry and mixed cropping. Direct support payments to farmers applying those cropping systems should be favored over the current price support measures (see the section on wa-ter, air and soil (agriculture)). This should be accompanied by awareness-raising measures on the importance of diversification of crops as a safety net for livelihoods in times of fluctuating agricultur-al commodity prices. Another instrument the MoE could use to incentivize the use and production of sustainable feedstock, is linking the current economic incentives for downstream processors (like the adder scheme for bioenergy and tax exemptions for biofuels) to the sourcing of feedstock. Brazil’s implementation of the Social Seal provides an interesting example in this regard. As a pre-condition

114

Further information can be found at: http://www.fao.org/energy/82318/en/

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to access biofuel subsidies, the Social Seal requires biofuel producers to source a certain share of their feedstock from family farms and to provide capacity-building support to those farms.

Promoting research on technology for second and third generation biofuels technology and their implementation could contribute to reduced concerns about the impacts of the Thai bioenergy policy on food security. These technologies, based on agricultural waste or non-food crops as feedstock, are favored in the RSB framework. As soon as such technologies become technically and economically viable they should play a role in reaching the goals of the AEDP. The MoE could provide the econom-ic incentives to make the technology viable for application (e.g. higher adder).

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5. Conclusions

Thailand’s agricultural sector is well developed, an important contributor to the economy and pro-vides employment in rural areas. Ambitious goals for alternative energy development, based on the need to reduce energy dependency on oil imports, combined with an effective policy framework to promote bioenergy, led to the rapid growth of the bioenergy sector. Promoted by mandatory admix-ture quotas, ethanol (mainly derived from sugarcane molasses) and biodiesel produced from palm oil replace a significant amount of liquid fuels for transportation. Electricity generation from biomass has increased steadily over the past years and is used within agricultural processing facilities as well as being fed into the electricity grid. Main feedstocks are bagasse from sugar production and rice husk.

Currently (2013), a five percent (5%) admixture of biodiesel for diesel fuel and ten percent (10%) admixture of ethanol for regular petrol is mandated in Thailand. The production of ethanol related to the mandate is 2.46 mio l/d and 3.04 mio l/d for biodiesel respectively (2012). The current total in-stalled capacity of electricity generation from biomass amounts to 1,818 MW (2012). In the AEDP, the Thai government aims at increasing ethanol production to 9 mio l/d and biodiesel production for conventional biodiesel to 5.97 l/d by the year 2021. In addition, it aims for a so-called ‘new genera-tion diesel’ production of 25 mio l/d by 2021, which is currently not produced in Thailand.

While the goal for ethanol production is considered by the Thai government to be achievable through increasing yields of cassava and sugarcane on existing land, the expansion of oil palm plantations is seen as necessary to reach the biodiesel goal and especially the goal for new generation diesel. The Thai government sees the largest potential for new generation diesel in bio-hydrogenated diesel (BHD) from palm oil and algae, which currently does not exist in Thailand. Current scenarios of the MoAC regarding achieving the policy goal for 2021, estimate that 1.5 mio rai (240,000 ha) for algae cultivation and 7.8 mio rai (1.25 mio ha) of oil palm are required to reach the production capacity of 12.3 mio l/d from algae and 12 mio l/d from palm oil. Considering that the current area planted with oil palm is 4.3 mio rai (688,000 ha), this could only be achieved by a vast and rapid expansion of oil palm plantations. This will most likely happen on areas currently used for rice production. Further-more, rapid advancements in technology development would be necessary for the production of BHD from algae and palm oil. The targeted electricity generation of 4,800 MW for 2021 constitutes a dou-bling the currently installed capacity. Hence, investments in further power plants are expected to occur. This could happen relatively quickly, considering the power purchase agreements that have already been signed as well as the proposals for bioenergy projects which have been approved and submitted – all of which already have a combined installed capacity to over 4,000 MW.

A number of sustainability concerns and challenges have emerged that are related to bioenergy ex-pansion in Thailand. The evidence of these concerns is based on research, analytical documentation and the stakeholder forum that was held in Bangkok in September 2013. Some of the concerns are directly related to bioenergy, whereas others are relevant to general agricultural production for any kind of feedstock use. The main direct impacts result from power plants using biomass as a feed-stock. Those impacts are localized to communities where production facilities are established and where the population suffers from air pollution, increased road traffic, loss of community land, stress on local water resources and reduced availability of biomass for other purposes like organic fertilizer. Processing plants for the production of liquid biofuels (ethanol) or their feedstock (palm oil) also pose direct sustainability risks. They emit large amounts of wastewater which requires adequate treatment to mitigate or avoid negative environmental impacts. Although wastewater from industrial processing is well covered by government regulations, negative impacts do occur where government authorities lack the capacity or willingness to ensure implementation. While there is still potential for improving the GHG balance of bioenergy produced in Thailand, the overall picture is positive and

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several studies have confirmed emission advantages of bioenergy over fossil fuels to be conform to the EU RED GHG reduction requirements for sustainable biofuels.

Sustainability impacts from agricultural production on the macro level cannot be directly attributed to bioenergy production, as until now a relatively small share of the main feedstocks has been used for bioenergy, and the by-products have been used for electricity generation and ethanol production (as in the case of bagasse and molasses from sugarcane). More than thirty percent (30%) of palm oil production is currently (2012) used for biodiesel production. All three major feedstocks are also ex-ported, which leaves space for replacing exports with domestic use of bioenergy production. Reaching the policy goal for ethanol, biodiesel and new generation diesel, however, will require that targeted yield increases in cassava and sugarcane production are met and that the area planted with oil palm is significantly increased. Increases in yields could require that larger amounts of fertilizers are used and irrigation is expanded. These practices entail certain sustainability risks, such as stress on water resources. Expanding the area grown with palm oil will require the conversion of land currently planted with other crops or forest. This could have negative effects on the GHG balance of biodiesel and possibly threaten conservation objectives. Sustainability concerns related to the agricultural sector in general include the working conditions of farm workers (especially migrants, who are cur-rently not adequately protected by law) and the adequate monitoring of informal farm work by the responsible authorities. Furthermore, violent land conflicts between agricultural companies and local communities have been reported, although the main concerns regarding land issues in Thailand are related to the rights of indigenous people and the governance of protected areas.

Agricultural development in Thailand over the last decades came at a high cost to the environment. In response to increasing environmental degradation, protection of natural resources has been im-proved since the 1990s and the regulatory framework for environmental protection in Thailand is now considered to be well advanced. Implementation, however, is lacking and encroachment of pro-tected areas is a serious problem which the government aims to address through the use of new tech-nologies. Soil degradation and stress on water resources resulting from the use of large amounts of fertilizer and pesticides is another issue of concern where little improvements have been made de-spite government efforts to promote more sustainable agricultural practices115. In sugarcane produc-tion in particular, open burning is reported as a major problem with negative impacts on air and soil quality as well as GHG emissions. Working with farmers to find practical solutions and alternatives that balance economic, social and environmental considerations poses a key challenge in Thailand.

To meet the AEDP policy targets for ethanol, biodiesel and electricity generation from biomass, a significant increase in sugarcane, cassava and palm oil production is required. Managing the in-creased feedstock demand without placing additional stress on natural resources requires a solid policy framework for environmental protection as well as stringent enforcement. More efficient and sustainable agricultural practices are necessary to meet the required feedstock demand. Agricultural extension measures that can reach out to a large number of small-scale producers are crucial to en-sure that sustainable practices are implemented and that government regulations are followed. Sup-porting farmers to adjust to the changing market conditions resulting from bioenergy promotion and the enforcement of labor standards in the agricultural sector is another pre-condition for positive impacts from bioenergy promotion on rural development.

For the same reason, effective policies need to be put in place to avoid potential negative impacts on food security, especially because the available land is limited. This is despite the fact that Thailand is not currently facing issues of food insecurity as it would prevent the emerging of any negative im-pacts.

115

Tirado et al. (2008).

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Greater local participation in the design of bioenergy projects like biomass based power plants, inde-pendent impact assessments conducted prior to project approval and stricter implementation of ex-isting regulations could ensure that benefits for communities are maximized instead of favoring pro-jects developed by external investors focusing solely on economic returns.

Thailand has committed towards a path of development that is sustainable. It has shown much pro-gress over the last decades in putting in place laws and regulations to protect the environment and improve the rights of local communities as well as workers. This existing regulatory framework is a good basis for the development of a sustainable bioenergy sector. However, some issues which are part of the RSB framework remain to be addressed by adequate regulations. They mainly concern the improvement of local participation in the development of bioenergy projects and the protection of agricultural workers producing bioenergy feedstock. In addition, stakeholders are calling for more consistency in the policy on alternative energy development to increase certainty in planning.

Despite the elaborate regulatory framework, their implementation and enforcement remain a chal-lenge. The reasons for this can be manifold and would require further detailed investigation and analysis. However, there are indications that implementation is hindered by overlapping responsibili-ties of the different authorities and a lack of reconcilement of regulations from those different author-ities. The lack of a consistent and transparent database on land classification and ownership was identified as an important impediment to the effective enforcement of the environmental conserva-tion framework and the land governance system. This needs to be addressed in a coordinated manner that involves different ministries and local authorities.

It remains a challenge to put into practice regulations and policy ambitions when the conditions in the field depend on a large number of small-scale farmers and enterprises. To meet this challenge, innovative approaches like cooperation with the private sector or conditional subsidies to replace current unsustainable farmer support schemes deserve further attention. Advancements of such ef-forts need to be monitored, evaluated and fed back into the policy making process.

Any policy measure needs to be consistent to allow long-term investment of stakeholders in the bio-energy sector. The basis for a policy framework that stimulates the sustainable development of the bioenergy sector in Thailand, should be clear and easily accessible incentives for sustainable practices as well as strict enforcement of regulations providing safeguards for sustainability.

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Appendices

Appendix 1. List of stakeholders interviewed

Date Name Organization Position

13.5.2013 Preparatory Meeting with Phannee Sinsuphan and Jonas Dallinger

14.5. 2013 Prof. Shabbir H. Gheewala The Joint Graduate School of Energy & Environment (JGSEE)

Lecturer and Researcher on LCA, GHG balance of agri-products

14.5. 2013 Dr. Boonrod Sajjakulnukit JGSEE Lecturer of Energy Division

15.5. 2013 Mr. Pongsak Prommakorn Department of Alternative Energy Development and Efficiency (DEDE) (Ministry of Energy)

Engineer, Biofuel Development

15.5. 2013 Mrs. Natthaporn Promma-korn

DEDE Scientist

15.5. 2013 Mr. Supalerk Kanasook German International Coopera-tion (GIZ)

Project Manager, Renewable Energy and Energy Efficiency in South-East Asia

16.5. 2013 Mr. Thanes Rajatapiti The Shell Company of Thailand Limited (Shell)

Bitumen Business Manager, Thailand, Laos and Cambodia

16.5. 2013 Mr. Supanai Pornsansirikul Shell Supply Contracts Manager

16.5. 2013 Mr. Sirivuthi Siamphakdee Association of Thai Ethanol Man-ufacturing (ATEM)

Chief of the ATEM

16.5. 2013 Mrs. Sudarat Tachasriprasert Thai Office of Agricultural Eco-nomics (OAE)

Expert, Tree Crops and Bioenergy

17.5. 2013 Mr. Khanchit Chaisupho GM Thailand Director, SEA Public Policy and Vice Chairman of the Thai Automotive Manufacturers Association

17.5. 2013 Mr. Phichai Tinsuntisook The Federation of Thai Industries Chairman, Renewable Energy Industry Club

17.5. 2013 Mrs. Sodsai Srangsok Kamsangsai Village, Ubonra-chathani Province

Community Leader to protest against a biomass plant

17.5. 2013 (phone)

Mr. Asirawat Thai Industrial Standards Insti-tute [TISI]

Secretary, Renewable Energy Academ-ic/Information Committee of TISI

Canceled

14.5. 2013 Ms. Kwunjai Chotsuwan Supreme Renewable Energy Co. Ltd.

General Manager

17.5. 2013 Associate Prof. Sitanon Jesdapipat, Ph.D.

Rangsit University Lecturer, College of Social Innovation at Rangsit University and Policy Plan-ner to ONEP

Followed up

12.6. 2013

Mr. Supakit Nuntaworakarn Healthy Public Policy Foundation Energy Analyst

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Appendix 2. Key stakeholders on sustainable bioenergy in Thai-land

This document comprises two elements. First (1) Thai key stakeholders are mapped and arranged, according to influence and importance in the process of regulatory and policy assessment on sustainable bioenergy. Second (2), a more elaborate list of the different involved stakeholder groups is provided. The figure below roughly depicts the four categories of Government agencies (G), Private sector (P), Civil society or NGOs (C) and Researchers (R).

Source: Aidenvironment (2013).

(1) Stakeholder Mapping

The following figure shows an overview of the key stakeholders involved in the regulatory and policy as-sessment of sustainable biofuels in Thailand. By using an influence and importance matrix, the figure anal-yses the stakeholders according to their importance and priority (CDI, 2012).116 Below the figure, it is briefly

explained what is meant by influence and importance of stakeholders as well as which implication this has for the classification of the stakeholders.  

116

Reference: Centre for Development Innovation, Action Oriented Research Training on October 2012, Wageningen University.

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Importance

The priority given to satisfying stakeholder’s needs and interests through the project. Stakeholders are interested in the project and converge closely with the project’s objective.

Influence

The power that stakeholders have over a project, such as to control what decisions are made, facili-tate its implementation, or exert influence which affects the project negatively.

The extent to which the stakeholder is able to persuade others into making decisions, and following certain course on action.

Implication A – Stakeholders in A require special initiatives if their interests are to be protected. B – The project needs to construct good working relationships with these stakeholders. C – These stakeholders may be a source of significant risk and may need careful monitoring and manage-ment. D – These stakeholders are unlikely to have an important role in the project activities or management. However, they might become more important when the context change in the future.

• G – NESDB/ DOEB/PCD• P – FTI• C – GIZ/TCJ/FGS/ FAO/

P-MOVE/TEI/ HPPF• R – CSI-RSU/ BAU-

CMU/ JGSEE

• G – DIW/DEQP

• P - TAIA

• G – ONEP/ EPPO/ DEDE/ ERC/ TISI

• P – ATEM/ TBDA/ TPOMA/ Shell/ Bangchak/ PTTGE/ Mitr

• G – OAE/ LDD/ ALRO

• P – BioEnergy/ Scania/ DoubleA/ EE/SRE

• C – BioThai/ Earth/ ABMN/ E4E/ AAN A

Hi imp./

Lo inf.

B

Hi imp./

Hi inf.

C

Lo imp./

Hi inf.

D

Lo imp./

Lo inf.

Policy making for sustainable Biofuels

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(2) List of Key Stakeholders

The tables on the following pages give an extensive overview of Thai institutions that are involved in the countries’ regulatory and policy assessment of sustainable biofuels, including government, private, civil society, NGO and research entities. Government agencies (G)

G Organization Brief description Key role of organization

1 National Economic and Social Development Board (NESDB)

Core planning agency responsible for national strategy formulation towards balanced and sustainable na-tional development and balancing economic, environmental and social impacts. Prepared 11th National Economic and Social Development Plan (2012-2016).

Policy maker

2 Office of Natural Resources and Environmental Policy (ONEP)

Agency, under the Ministry of Natural Resources and Environment (MoNRE). Prepares and implements integrated policy, planning and mechanisms for Natural Resources and Envi-

ronmental management Take part in BioEnergy policy to measure and monitor Environmental Impact Assessment (EIA), Envi-

ronmental Health Impact Assessment (EHIA) and Initial Environmental Examination (IEE).

Policy maker/impact moni-toring

3 Office of Agricultural Economics (OAE)

Principal organization under Ministry of Agriculture and Cooperatives (MoAC). Undertakes economic and social research and other studies M&E for agricultural policy recommendations, and agricultural development planning. Streamline bioenergy plans into agricultural development plans.

Agricultural Policy and Planning, Integration of Departments in the MoAC

4 Energy Policy and Planning Of-fice (EPPO)

Main institution under the Ministry of Energy (MoE) to formulate the overall Thai energy policy and regu-late Thai electricity prices Responsible for monitoring of energy policy and management plans (alternative energy and energy ef-

ficiency). Manages oil fund, conservation fund and funds energy policy related research.

Policy maker

5 Department of Alternative Ener-gy Development and Efficiency (DEDE) (Ministry of Energy)

Responsible in the MoE for ensuring implementation of Thai policy on renewable energy and energy effi-ciency. Tasks include: Sets and implements overall policy, includes alternative energy Developed the 10 years Alternative Energy Development Plan (AEDP) 2012 – 2021 for Thailand.

Policy maker/implementer

6 Energy Regulatory Commission (ERC)

Independent regulative body for energy sector in Thailand. Operates under the Energy Industry Act of 2007. Ensures equal and fair treatment of consumer, pro-

ducers and other stakeholders in energy sector.

Policy maker

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7 Department of Energy Business (DOEB)

Government institution involved in Thai policy on energy and alternative energy. Responsible to interact with private sector and ensure implementation of quality and safety standards

Implementer/impact moni-toring

8 Pollution Control Department (PCD)

Under Ministry of Science and Technology (MoST) in charge of Pollution Control. Tasks include: Controls, prevents, reduces and eliminates pollution Conserves and rehabilitates environment

Implementer/impact moni-tor/observer

9 Department of Industrial Works (DIW)

Works under Ministry of Industries (MoI). Monitors operations for efficiency of factories, improve the quality and quantity standard and maintain

price levels of the products manufactured at factories supplied to the public. Responsible for monitoring environmental impacts from industrial operations

Implementer Impact monitor/

10 Thai Industrial Standard Insti-tute (TISI)

Works as national standards body of Thailand, within the Ministry of Industry. Promotes and develops industry, maximizing benefits for entrepreneurs, consumers and the nation as a

whole. Standardization (i.e. ISO, IEC, FAO/WHO CODEX). Develops industry standards, represents Thailand in the ISO

Implementer/ Impact monitor/observe

11 Department of Environment Quality Promotion (DEQP)

Works under the Ministry of Natural Resources and Environment (MoNRE), as national environmental information centre. Compiles, develops and promotes use of environmental databases Coordinates and formulates plan and measure, to promote and disseminate protection of national re-

sources and environment.

implementer Impact monitor/observe

12 Land Development Department (LDD)

Works under the Ministry of Agriculture and Cooperatives. Tasks include: Establish land use zoning to enhance agricultural productivity, and the provision of accurate and up-

dated spatial data, develop basic infrastructure on land development, Increase agricultural productivity and sustainable land use. Launch of land use zoning policy that indicates suitable areas to plant cassava, para rubber, sugar cane

and corn on 9 February 2013.

Research and policy rec-ommendation

13 Agricultural Land Reform Office (ALRO)

Works under the MoAC. Conducts land allocation for farmers under the Agricultural Land Reform Act. Supports construction and maintenance of access road and water resources, to improve farmer liveli-

hoods agriculture.

Implementer

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Private Sector (P)

P Organization Brief description Key role of organization

1 Renewable Energy Industry Club - Federation of Thai Industries (FTI)

Main mission: to consolidate and strengthen manufacturers, through: Representation of alternative energy producers in Thailand (Solar cell, Wind, Biomass, Biogas, Etha-

nol, Biodiesel and Waste) Encouragement of the exchanges of data and information, capacity development Technology transfer in all industries Recommendation for policies, laws, rules, regulations and procedures.

Industry Representation / Lobbying

2 Association of Thai Ethanol Manufacturing (ATEM)

Representation of Thai Ethanol producers from tapioca, sugar cane and molasses. Coordinates agreements with third parties for mutual benefit of Thai Ethanol Manufacturing enterpris-

es Monitors & tracks the movement of the Ethanol trading market (inter)nationally

Industry Representation / Lobbying

3 Thai Automotive Industry Asso-ciation (TAIA)

Represents the automotive industry of Thailand. Member of Renewable Energy Industry Club, promoting Ethanol and Biodiesel in public bus to the pol-

icy level. Dialogue with government on the use of biofuels / admixture quota

Industry Representation / Lobbying

4 Thai Biodiesel Producer Associa-tion (TBPA)

Association of 10 Biodiesel producers. Supports & develops biodiesel business Information center collaborates with government bodies. Participated in setting up of National Interpretation on RSPO.

Industry Representation / Lobbying

5 Thai Palm Oil Crushing Mill As-sociation (TPOMA)

Supports palm oil industry at mill level To produce low carbon footprint CPO, Promotes renewable energy i.e. biogas, biomass plant, biodiesel oil.

Industry Representation / Lobbying

6 The Shell Company of Thailand Limited (Shell)

International petroleum company providing biofuels to consumers Dedicated to sustainable sourcing practices, Shell has a preference for robust multi-stakeholders

schemes such as RSPO.

Implementer

7 Bangchak Biofuel Affiliated to one of leading Thai petroleum companies Bangchak Petroleum Plc Focuses on biodiesel production and green energy.

Implementer

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Civil society or NGOs (C)

8 PTT National Oil and Gas conglomerate, global fortune 500 company majority owned by the Thai Ministry of Finance Biodiesel production by subsidiary PTT Green Energy Strong influence on Thai policy making

Implementer

9 Mitrphol Biofuel Part of the Mitrphol Group, Thailand’s largest sugar producer largest ethanol producer and exporter,

Implementer

10 Bio-Energy Co. Ltd. Mitr Phol subsidiary. Runs biomass power plants. Implementer

11 Siam Scania International company with presence in more than 100 countries. Leading members to support Ethanol-Biodiesel bus project in Thailand together with Renewable Ener-

gy Industry Club.

Implementer

12 Double A Ethanol Part of the Double A Company Group, a leading pulp and paper producer in Thailand Producer of Ethanol from Cassava

Implementer

13 Eternal Energy Plc. (EE) Producer of Ethanol from Cassava Implementer

14 Supreme Renewable Energy Co. Ltd. (SRE)

First biomass power supply producer using the “Gasification” technology Produce electricity using agricultural residuals from farming activities and waste wood in the local

communities, to increase income.

Implementers

C Organization Brief description Key role of organization

1 German International Cooperati-on (GIZ)

GIZ is a federally owned German International Cooperation enterprise for sustainable development with worldwide operations. Since 2013, GIZ has launched the Project Development Programme South-East Asia (PDP-SEA) -Renewable Energy. The project aims to support the Thai Ministry of Energy through close co-operation with the Department of Alternative Energy Development and Efficiency (DEDE).

Technical or knowledge facilitator/ supporter

2 Thai Climate Justice Working Group (TCJ)

TCJ was formed by an NGO network in Thailand (i.e. Earth foundation, BioThai Foundation, Focus on the Global South, Foundation for Ecological Recovery, Sustainable Agriculture Foundation and Sustainable Development Foundation), to raise awareness on Climate Change to the public, including monitoring and giving policy recommendations at the national and international level.

Impact monitor/observer

3 BioThai Foundation Conduct Research and promote bio-agricultural resources and community based farmers' rights. Impact monitor/observer

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4 Focus on the Global South (FGS) Focus on solidarity with the Global South. Works in the region on farmers’ rights and impacts of globaliza-tion.

Impact monitor/observer

5 Ecological Alert and Recovery - Thailand (EARTH)

EARTH is an environmental non-governmental organization, striving for environmental and social justice by monitoring, research, campaign and advocacy on public policies related to industrial development, in-dustrial pollution, hazardous chemicals, wastes, and health impacts on society, workers, environment, and the society.

Impact monitor/observer

6 Food and Agriculture Organiza-tion Regional Office for Asia andthe Pacific (FAO)

FAO helps countries promote energy-smart agrifood systems through the identification, planning and im-plementation of appropriate energy, water, food security and climate-smart strategies that spur agricultural growth and rural development. Runs bioenergy and food security (BEFS) project in Thailand Aims at helping Thailand to design and implement sustainable bioenergy policies and strategies

Impact monitor/observer

7 Anti-Biomass plant network (ABMN)

Network of communities affected by biomass plants. Main recommendations of the network include: Community managed small-scale biomass < 1 MWT Conduct impact study by community and field feasibility study Develop zoning or town planning that can mitigate the impacts in agricultural area. Support community participation Recovery measurements to those who get affected by Biomass

Impact monitor/observer

8 Energy for Environment Founda-tion (EforE)

Promotes the use of renewable energy Provide knowledge on renewable energy Research on biomass utilization

Lobbying

9 The anti-government People's Movement for a Just Society (P-Move)

Network works to bring justice for marginalized groups in Thailand, including land rights for small-scale farmers, citizenship for stateless persons, fair compensation for communities forced to relocate to accom-modate large scale state projects, and housing solutions for urban slum dwellers, among others.

Impact monitor/observer

10 Thailand Environment Institute (TEI)

TEI is a non-profit, non-governmental, environmental organization that helps to formulate environmental directives and link policy with action to encourage meaningful environmental progress in Thailand.

Technical or knowledge facilitator/supporter

11 Alternative Agriculture Network – Esan (AAN)

Works to develop sustainable agriculture techniques based on the local ecology Concerns about the impacts of ethanol promotion and contract farming in the sugar industry

Impact monitor/observer

12 Healthy Public Policy Foundation (HPPF)

Focus areas: Energy Green Health by community participation Climate Change Public Participation & Health Impact Assessment in Alternative Energy Development National Progress Index Program.

Impact monitor/observer

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Researchers (R)

R Organization Brief description Key role of organization

1 Biogas Advisory Unit, Chiang Mai University (BAU-CMU)

Launched the National Biogas Dissemination Program for the medium and large scale livestock farms Stimulate increased renewable energy use and farm discharges.

Technical or knowledge facilitator/ supporter

2 Joint Graduate School of Energy and Environ-ment (JGSEE)

International graduate education and research school operating as a consortium involving leading Thai institutions: KMUTT, KMITNB, PSU, CMU and SIIT-TU. Their research expertise is in the fields of energy, environmental technologies and management. Relevance research area are follows as for instance, Energy and environmental policy and management Renewable energy resource utilization and promotion policy Integrated environmental assessment of energy, particular renewable energy Biofuel production related technology

Technical or knowledge facilitator/ supporter

3 Associate Prof. Dr. Sitanon Jesdapipat College of Social Innovation, Rangsit University (CSI-RSU)

Lecturer at CSI-RSU. Research on environmental economics and policy analysis, environmental impact assessment, and cli-

mate change policy. Senior advisor for the committee on Environmental Impact Assessment and a member of the commit-

tee on Biodiversity Policy.

Policy maker/Technical or knowledge facilitator/ sup-porter


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