RSB Public Consultation (Version 1.1) - Principle 1
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Roundtable on Sustainable Biofuels > RSB Public Consultation > RSB Public Consultation (Version 1.1) - Principle 1
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This page is provided to assist the public consultation conducted by the Roundtable on Sustainable Biofuels concerning the proposed Version 1.1 of the RSB Principles and Criteria. This page will be used for information and comments related to Principle 1. To download Version 1.1 of the RSB Principles and Criteria, please click here.
| Commenting Instructions for the RSB Public Consultation | edit | |
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- Note: In most cases, comments were uploaded by User:Admin and edited/reformatted for consistency and clarity, as necessary.
Principle and Criterion 1
Comment from the Brazilian Sugarcane Industry Association (UNICA):
- "It is important to mention that only international conventions that were ratified by the country are going to be considered in this criterion."
- Rationale provided: "Sometimes a convention is not ratified because it can contravene a national law."
Comment from the Canadian Renewable Fuel Association (The comment has been uploaded by User:Admin):
- "The proposed changes seek to add flexibility to the Principle. This is appropriate."
Guidance for Principle 1
Comments from the Center for BioEnergy Sustainability, Oak Ridge National Laboratory:
- "General Guidance, 3rd bullet: Language of new guidance was not clear. Would this better articulate the intended guidance?"
- "Documented compliance with applicable laws, regulations and relevant international conventions and treaties identified in Principle 01 can be used to show full or partial compliance with other RSB Principles & Criteria." [Such cases can be specified here and referenced in subsequent principles and criteria.]
Comments from Universidade Federal Rural da Amazônia:
- "1st bullet point. Suggest rephrasing as: "Applicable laws include those related to the social and environmental sustainability criteria outlined in this standard, including but not limited to regulations and measures governing land tenure and land rights, labor, waste disposal, chemical use, and environmental and knowledge protection."
Comments from JDMT:
- "Cross-equivalence in interstate, international and global project development is indeed critical. Correspondingly, lack of equivalent provisions when moving in project assessment and certification from local to RSB will always be an area of contention. Addressing this aspect now with exemplary comparisons of assessment protocols would be advisable. I might suggest as a very first step, a matrix equivalence between RSB protocols and the U.S. National Environmental Protection Act, or NEPA."
Comments from RSB, Chamber 6:
- "Page 4 - In the latest version of the document an insertion has been made: “Some of the applicable laws, regulations and relevant international conventions and treaties identified under Principle 01 can also be used to show full or partial compliance with the RSB Principles & Criteria.” Chamber members expressed strong concerns about the practical implication of this change. It has also been concluded that the rationale presented for this change is vague. Either remove this insertion or clarify the applicability of this option."
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