RSB Public Consultation (Version 1.1) - Principle 12
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Roundtable on Sustainable Biofuels > RSB Public Consultation > RSB Public Consultation (Version 1.1) - Principle 12
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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 12. To download Version 1.1 of the RSB Principles and Criteria, please click here.
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- Note: In most cases, comments were uploaded by User:Admin and edited/reformatted for consistency and clarity, as necessary.
Contents |
Principle 12 -- Comment(s) received
Comments from Alcosuisse:
- "We would like to highlight possible duplication issues between Principles 2 and 12. What is the difference between ESPM (principle 2) and compliance with the land rights and land use rights? This needs to be clarified."
Comments from the Canadian Renewable Fuel Association:
- "The CRFA agrees that biofuel production shall respect land rights and further agrees that the fact that a dispute is in legal process does not necessarily define it as legitimate. The process for determining the legitimacy of disputes could be further elaborated."
Criterion 12a -- Comment(s) received
Comment from CADER:
- "In first bullet point, replace '• If existing land rights and land use rights are potentially impacted by biofuel operations a Land Rights Impact Assessment (RSB-GUI-001-007) shall be conducted.' by 'If the screening process of the RSB impact assessment reveals a negative impact to existing land rights and land use rights by biofuel operations, a Land Rights Impact Assessment (RSB-GUI-001-007) shall be conducted.'"
- Rationale given: "Make clear that negative results in the preliminary screening process are the determinants for more specific impact assessment."
Criterion 12b -- Comment(s) received
Comment from the Center for BioEnergy Sustainability, Oak Ridge National Laboratory: [the following 3 comments are not on changed text but are intended to make other parts of the document consistent with the changed text]
- Criterion 12b.1 Minimum Requirements, 4th bullet: Should “relinquishment” be changed to “relinquishment and/or acquisition” as in the other bullets?
- Criterion 12b.1 Minimum Requirements, 5th bullet: Given that legal counsel cannot be independent if paid for by the opposing party, then is it reasonable to refer to independent land valuation specialists? Also, somewhere else a word like “certified” was removed because there was no certification process in place for that type of specialist. Would the same logic apply to “qualified” here?
- Criterion 12b.1 Minimum Requirements, 6th bullet: This seems redundant with the new language in the 3rd bullet.
Comments from Boeing:
- "12.b.1.Last bullet point. Strongly support deletion."
- "As stated, there is an inherent conflict of interest in such a provision."
Guidance on Principle 12 -- Comment(s) received
Comment from the Center for BioEnergy Sustainability, Oak Ridge National Laboratory:
- General Guidance, 4th bullet: Not all operators need to do an ESIA. In other places this type of language has been changed to say “impact assessment” to refer to the whole process.
Comment from DNV:
- "12a. 'Legitimacy of the dispute shall can be determined by the auditor using the RSB guidelines and reliable information from the operator.'"
- Rational: "There needs to be clear guidelines as to what a legitimate dispute is."
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