Talk:RSB Public Consultation
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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 general comments and discussion. To download Version 1.1 of the RSB Principles and Criteria, please click here.
- To add a comment, click on the plus sign (+) above to bring up the edit box where you can type in your subject and comment. Please be sure to add your name and affiliation, so that your comments can be considered officially.
- Note: In most cases, comments were uploaded by User:Admin and edited/reformatted for consistency and clarity, as necessary.
Comment from Gasification Australia Ltd.
- "RSB seems to not define 1st, 2nd and 3rd generation biofuel systems. The documents I have read show lack of understanding of processes other then 1st gen biofuels.
- "We in Australia are discussing biofuels as part of landscape restoration. Why is this not brought up here?
- "Australia is a largely degraded landscape and 2nd-generation biofuel systems -- that is, products/energy derived independent of biomass resources -- gives flexibility to find resources that can also facilitate other valuations (e.g., timber production, biodiversity, etc.). RSB is losing sight of the potential to directly (in synergistic ways) affect multiple outcomes from directly beneficial outcomes derived via compatible (forestry) native ecosystems reintroductions -- particulary to assist landscape refragmentation.
- "Where do I discuss these pathways?"
Comment from Sierra Club
- "I suggest a scoring ranking system that works something like this: entities seeking a rating can enter a self-determined ranking that would be expressed as # - # - # (and perhaps more numbers). The first number would stand for whether or not the facility was located in a political jurisdiction which has regulatory oversight of sustainability. 0 is none. 2 is regulation without enforcement. 1 is regulation with enforcement. The second number would stand for whether or not the facility obtains all its fuel from within a political jurisdiction which has regulatory oversight of sustainability. If it obtains all its fuels from more than one political jurisdiction, then each jurisdiction would be assigned a separate number separated by a comma, and the numbers would be presented in alphabetical order of the names of the jurisdictions. In theory, many jurisdictions could be identified. The third number would be based on the RSB Principles and Criteria. I suggest that the scale be inverse - if all 12 criteria are met, then the number is zero, and if eight of them are met then the number is 4, with the option to use commas as for the second number.
- "My perspective is tempered by my active involvement in woody biomass to electricity projects. They cannot possibly meet the test of less carbon than fossil fuels, but the fear we have is more dependent on the fact that right now the Ohio regulators have granted certification as producers of renewable credits to about twice as many projects as can be fueled with Ohio's annual forest product growth, if you first discount the forest products already being used by paper, lumber and firewood activities. So I view the RSB principles as raising the question as to whether a sustainable ethanol plant based on Brazilian sugar cane can be ranked as sustainable if Brazil is still harvesting rainforests unsustainably. Such a ranking as I propose would facilitate better communication about these matters, whether or not they would be helpful in changing the paradigm.
- "It is impossible to determine true sustainability without a complete inventory of all land, which measures both agricultural land and forest land, measures changes in land use especially from productive to nonproductive (and vice versa in a few rare cases) and identifies the total annual biomass growth rate AND establishes a condition that ensures that annual harvest is less than annual growth, including biomass left on fields or in forests to ensure sustained soil health in the wake of harvest. Even there, we have grey areas such as soil erosion and loss of soil carbon content, but it would be good to have only those uncertainties."
Comment from Boeing
- "Suggest that RSB combine the Criteria and Guidance documents."
- Rationale: "To improve user clarity and cohesiveness. Multiple documents requiring continual cross-referencing are cumbersome to use."
Comment from Center for BioEnergy Sustainability, Oak Ridge National Laboratory
- "RSB seems to have tried to take out all normative language from the Guidance document, but this has not been completed. There are still a few instances of “must” and a few dozen instances of “shall” that can easily be found using MS-Word’s search function."
- "RSB also seems to have tried to change all instances of “operator(s)” to “Participating Operator(s)”, but this too is incomplete. The remaining instances can be found by searching for “operator”. This comment applies to both the Guidance and Principles & Criteria documents."
- "The term “scoping exercise” is used several times in the Guidance document, but this term is not defined and is absent from the Principles and Criteria. Was “screening” meant?"
Comment from Brazilian Sugarcane Industry Association, UNICA
- "The document provided by the RSB on feedback from pilot projects does not give quantitative results and also does not indicate which methodologies and samples were used for auditing the RSB principles and criteria. Feedbacks received from operators and certification bodies have certainly contributed to the public consultation, but they did not provide practical and quantitative information on compliance that allows for the assessment of which aspects of the system has to be improved. In this sense, the comments presented here are limited to the ones that could be made without more detailed information on the pilot projects."
- "Version one of the RSB principles and criteria was approved for pilot testing. This means that based on the analysis of its feedback, we can agree on the exclusion, adoption or amendment of certain P&C. As we did not have the opportunity to discuss the results and feedbacks of pilot testing, we believe it is useful not to limit our comments strictly on the proposed changes, but rather on the document as a whole."
- "We suggest that the RSB system, as a voluntary certification initiative that is applicable at the operator level, should only adopt P&C that represent the most appropriate approach to tackle a given sustainability issue."
- "There is no reference in the "RSB Principle and Criteria" of the RSB being a meta-standard. We suggest that this information should be available in the document."
- "Indirect Effects: We understand that the way forward to deal with indirect impacts was not yet agreed by the RSB membership. The current approach was proposed by the RSB Secretary, but we believe it has to be approved by the RSB members before it is included in the standard."
Comment from JDMT
- "Consistency: If the P&Cs are to provide for certification of methods that promote “continual improvement”, then the language for each element of the P&Cs needs to stress that simply ”business as usual” is not acceptable, and the Guidance for the P&Cs similarly must explain why standard business practices are insufficient."
- "Feedstock Source: If the entire supply chain in the production of biofuels is to be considered, then the nature of the source of the feedstock should be taken into account. At no point in the documentation does the relevance of utilization of waste vs virgin stock enter into consideration, when indeed we can effect both a reduction in existing environmental damage and an improved alternative to current practice, by selectively favoring waste conversion."
- "Implementation: For ease of future interpretation, perhaps a compiled version, pairing Guidance clarifications directly with P&Cs in one text, would provide a more understandable format."
- "Curiously, no specific definitions of “Continual Improvement”, “Sustainable” or “Sustainability” are presented in this referenced Glossary. Although this sections has not been proposed for modification in this version, I would submit that many turn to the RSB for just this level of understanding. Please define these terms."
Comment from Alcosuisse
- "The criteria are quite detailed and cover a variety of areas. On the one hand, this is essential for an internationally recognized standard. On the other hand - as seen from the perspective from a trading company - we believe that there may be a risk of difficult implementation regarding the variety of principles."
- "The implementation of all principles requires a very high level of competences and resources, in various fields like time, technological knowledge, political and social influence and network, financial means."
- "Some criterions present the risk of being seen as obstacles to cost-efficiency targets (for example 2b)."
- "Page 5 of the RSB P&C's: the Standard effective date should be replaced by "1 January 2011" instead of "1 January 2010"."
Comment from the Sustainable Forestry Initiative
- "Public management plans: Instead of requiring public management plans, the RSB standard should require public audit summary documents. In the US, private companies own hundreds of thousands to millions of acres, which will encompass, a number of states, and hundreds of forest management units and forest types. It is highly impractical to expect a public summary of a management plan in this context, to provide any useful information. If the goal of certification is for the company to successfully implement a standard, then the public audit summary should provide enough detail to ensure this is the case."
- "Definitions: The current format of the RSB Standard makes it difficult to identify terms specifically defined for the RSB Standard. SFI Inc. recommends formatting defined terms so that the reader clearly knows that term has a specific meaning in the context of the RSB Standard."
- "Also, in reviewing the Standard, SFI Inc. noted that there are some terms in the glossary that are not used in the actual Standard (i.e. High Conservation Values). As the Standard has no doubt undergone a number of modifications, SFI Inc. suggests cross-referencing the glossary with the Standard to prevent confusion and ensure that only terms used in the actual Standard are defined in the glossary."
Comment from RSB Chamber 6
- "The implementation of the P&C in a real certification system is dependent upon the detailed indicators used to verify these. Chamber discussions especially related to Principle 7 revealed that there were concerns about the adequacy of certain indicators mainly because the text of the principles has changed. So will there be a specific opportunity later to amend the indicators on the basis of revisions to the P&C?"
- "On page 5 of the RSB P&C, the stated effective date of the Standard seems to be a mistake: the document states that Version 2 will become effective on January 2010. But Chamber 6 is concerned that this should not be construed to change the cut-off dates for certain criteria, such as 7a."
- "It has been noted that some documents referred to in the documents under consultation appear to have either different names or different versions posted on the RSB website. For example on page 5 of the RSB P&C there is reference to “Use of Terms for the RSB Principles and Criteria (RSB-DOC-01-001)”. On the RSB web site, what we assume is the same document is referred to as the “RSB Glossary of Terms, RSB-DOC-10-002” which is available for download. A solution would be to include a complete list of the documents with uniform current names, as referred to in the standard."
- "Several of the P&C may pose excessive hurdles for small producers, so Chamber 6 requests that a process of providing special consideration for group certification and other assistance for small producers be scheduled in the development of the RSB."
Comment from National Biodiesel Board
- "NBB commends RSB in launching pilot projects to assess the practical implementation of the RSB principles and criteria. The cost associated with measurement and reporting of social and environmental benefits could impinge upon the economic sustainability of participating operators. Small and innovative businesses can have significant environmental and social benefits, but may be challenged to compete economically with established industries like petroleum. NBB notes that many of the operators participating as part of the pilot projects are not currently producing and marketing biofuels. While it is important to gather the perspective of these companies that one day aspire to produce renewable fuels, NBB suggests that it is equally or more important to pilot the implementation of RSB principles and criteria with companies that physically produce biofuel and compete commercially in the existing marketplace. NBB urges RSB to include more actual biofuel producers in the pilot projects and work to accurately estimate the cost of becoming certified through RSB. As long as the administrative cost of getting certified remains in question, it cannot be known how RSB’s principles and criteria impact the economic sustainability of operators, and it remains questionable whether U.S. biodiesel producers will find value in RSB participation."
- "As noted in the introduction to Version 1.1, it is appropriate that RSB has delayed inclusion of indirect impacts. NBB objects to the statements in this introduction that state such effects must be included to properly account for biofuels impacts. The direct benefits of biodiesel are well documented. Assertions that negative indirect impacts may be significant have proven to be overstated. As scientists invest more effort in modeling the indirect land use change as a result of the U.S. biodiesel industry, science is finding those predicted indirect impacts to be decreasing and potentially positive. There is very real potential that the indirect land use change effects for biodiesel can be positive by displacing more carbon intensive land uses as a result of biodiesel production. If RSB includes indirect land use change emissions in the future, the guidance for Criterion 3c will need to be revised to remove the favorable generalization about feedstocks that avoid the use of land. Such generalization would not apply, if RSB includes the net positive GHG benefits of indirect land use change."
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."
- "In the introduction (p 2). This does not appropriately define compliance. On one hand, 'compliance is determined at the criteria level;' on the other, '[m]eeting the requirements under a specific criterion alone does not ensure compliance.' This is ambiguous as it appears to mean that the criteria by which compliance is judged are open-ended and subject to interpretation beyond the terms defined in the RSB Standard itself. For the standard to be effective entities considering participation must 'know what they are signing up for' – this is impossible to determine given that the criteria are open-ended.
- "In short, what is needed is not a statement of what does not ensure compliance, but a clear statement of what does ensure compliance."
- "In the introduction (p 3), This statement should be qualified – it is not clear whether future technological developments will allow biofuels to replace transport fuels without tradeoffs. Further, not all transport fuel sectors offer the same opportunities for replacement by biofuels – in the aviation sector, for example, relatively few distribution points serve a large percentage of users, providing the potential for introduction of biofuels without incurring tradeoffs (or the same level of tradeoffs) that may be required in other sectors."
- "The statement also can be read to mean that the development/introduction of biofuels will require “significant changes in lifestyle and efficiency of use,” which does not appear to be the intent of the statement and is not accurate."
Comment from IGES
- "Overall, we support the basic directon of the RSB process and system. Basically, it seems to be trying to set a relatively high standard, in its current form, and we support that overall direction. At the same time, it also appears somewhat complex, so we are wondering whether the system will benefit large producers to the disadvantage of small ones. This is an empirical question which can be answered by the experience of the pilot projects, and we strongly support the continuation of these pilot projects. Not much information has been revealed by the RSB about the pilot projects, although the available information apparently supports the overall conclusion that the system is essentially feasible, with a few clarifications here and there. We hope that the RSB will continue to monitor this issue as the pilot projects continue. We also hope that the work can continue on clarification of the guidelines and explanations."
Comment from SAFUG
- "SAFUG will be happy to work with the RSB throughout the piloting stage to ensure the standard is practical."
Comment from Canadian Renewable Fuel Association
- "Principle 3c was not piloted during the January – August 2010 period. This specific aspect of the Standard should be subjected to real world piloting to determine its feasibility and to improve it. Specifically, the participation of organizations involved in the global trade of biofuels should be actively sought."