RSB Public Consultation (Version 1.1) - Principle 9
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Roundtable on Sustainable Biofuels > RSB Public Consultation > RSB Public Consultation (Version 1.1) - Principle 9
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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 9. 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.
Contents |
Principle 9
Comment from Alcosuisse:
- "The use of technologies, inputs and management of waste is (should be) partially included in the soil, water and air principles."
Comment from the Canadian Renewable Fuel Association:
- "Similar to the comment for principle 6, the assessment of water impacts should take into account factors in addition to the biofuel industry that might impact this criterion. For example, a biofuels plant should not be penalized for depleting water resources if after the plant was constructed, a large water consuming industry was allowed to draw upon the same water source thereby depleting it. CRFA suggests that countries or regions with long-standing feedstock production practices, on a feedstock-specific basis, be able to fast track this Principle under an aggregate compliance scheme."
Principle 9.a
Comment from CADER:
- "In the 2nd bullet point, replace 'shall be assessed by the Participating Operator, and any negative impacts mitigated.' by 'shall be assessed by the preliminary screening process and any negative impacts mitigated by Participating Operator.'"
- Rationale given: "Consistency with the trigger for further analysis."
- "After 3rd bullet point, replace 'Participating operators that trigger the Water Rights Assessment (RSB-GUI-01-008) shall:' by 'Where the preliminary screening process has triggered the need for a Water Rights Impact Assessment (RSB-GUI-01-008), Participating Operators shall:'"
- Rationale given: "Consistency with the trigger for further analysis."
Comment from the Sustainable Forestry Initiative:
- "Water Management: Principle 9 contains criteria to maintain both water quality and quantity. Protecting water quality is an important part of forest certification programs. Harvesting operations must always utilize best management practices (BMPs) for water quality, which require that water bodies are not negatively impacted (i.e. changes in temperature, sedimentation). Also, those BMPs that are focused on wetlands, watersheds and protection of water resources also address water quantity and retention. Operations that would otherwise violate these requirements must be permitted by government agencies – and if they were to negatively affect water resources for the general public they would not be allowed. Generally forestry operations that qualify for forest certification would not be irrigated, nor would they utilize activities that would require a permit."
Principle 9.b
Comment from Oxfam International:
- "Replace last bullet point by: 'The Participating Operator shall undertake annual monitoring of the effectiveness of the water management plan, including investigating any community concerns related to impacts on water availablity or quality.'"
- Rationale: "The monitoring should not be merely of the effectiveness as defined by the operator, but also of the experience of the community regarding water availablity and quality after the development of the biofuel project."
Principle 9.c
Comment from CADER:
- "After 4th bullet point, replace 'Participating Operators that trigger the Water Impact Assessment (RSB-GUI-01-006) shall:' by 'Where the preliminary screening process has triggered the need for a Water Impact Assessment (RSB-GUI-01-006), Participating Operators shall:'"
- Rationale given: "Consistency with the trigger for further analysis."
Comment from the Center for BioEnergy Sustainability, Oak Ridge National Laboratory:"
- "Criterion 9.c.2 Progress Requirements, 1st bullet: Current language suggests that rain water harvesting is required of all operators. Is this intended? If rain water harvesting is presented as an example, it should be stated as such and moved to the Guidance document, as other examples have been."
Comment from IATA:
Disclaimer/Clarification: "Inputs from various organisations in the airline community were received, which are enumerated hereafter. Some of them are the opinion of individual organisations and are not necessarily supported by all IATA airlines involved in the biofuel topic and the IATA Secretariat."
- "Min reqt + guidance. Together, these illustrate the extraordinarily constraining potential for this Criterion: the Guidance essentially implies that any withdrawal of water from a watercourse will likely constitute a change in trajectory, which is prohibited by the minimum requirement."
- "This type of minimum requirement is likely, as a practical matter, to preclude the approval of operations that will rely on withdrawal of water from watercourses - this kind of overly rigid requirement is not appropriate."
Guidance on Principle 9
Comments from DNV
- "9a. Suggest rewording: 'Legitimacy of the dispute can be determined by the auditor against guidelines established by the RSB.'"
- Rational: "The auditor will determine if the information is sufficient to determine the legitimacy of the dispute based on the RSB guidelines (which must be clear). The auditor can request additional information if needed to determine the legitimacy of water disputes."
- "9c. Suggest rewording of: 'In the case where an aquifer or a water course is used by many operators, the contribution of biofuel operations to the overall impacts will be assessed by the auditor in charge of certification based on information provided by the operator that includes an overall water use plan of the area. If there is no plan available, other documentation will need to be made available that is suitable for determining total water use in an area.'"
Comments from Oak Ridge National Laboratory
- "Guidance on Criterion 9c, 6th bullet: The word “trajectory” has been removed from the P&C document."
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