Talk:ENV Draft Principles

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This page is dedicated to the comments and Questions/Answers about the Draft Principles on environment(RSB Working Group on Environment). The answers posted by the RSB secretariat are coloured in green.PLEASE REGISTER TO THE WORKING GROUP BEFORE EDITING THE PRINCIPLES

General Comments

1. Semantic/syntax problem with the use of "and/or." Strictly speaking, when "or" is used, "and" is implied.Kirk Leonard
   • Sometimes, only "and/or" has the precise meaning that the two propositions can be combined (what possibly strengthen them) and do not exclude each other.

Biofuel production should not directly or indirectly endanger wildlife species or areas of high conservation value

1. What happened to "biodiversity?" Neither "wildlife species" nor "high conservation areas" fully include it.Kirk Leonard
   • We disagree with this view since HCV areas cover both high and low biodiversity areas (cf: definition of HCV areas). Nevertheless, we had a concern that some wild species could also be harmed outside HCV Areas (during migration for instance) and that's why we added the wildlife species term. As per definitions found on the internet, wildlife includes all living species that have not been artificially modified or domesticated, from bacteria to animal, fungi, vegetal species and tutti quanti...
   • With respect to the protection of biodiversity, as I understood the original principle, “wildlife species” and “HCV” areas do nothing for the protection of existing organic or low-intensity farm lands, pasture lands, or natural meadows and other lands that may not be HCV areas or “wild” in any way, per se. I can also easily imagine someone looking at this new principle statement and concluding that extensive mono-cropping would be appropriate. I would prefer the original term “biodiversity” be retained, perhaps modified from “areas of high biodiversity” to a more simple and broader “ecosystem biodiversity,” with wildlife corridors and HCVAs cited as criteria elements, rather than the narrow statement proposed being a principle needing as much explanation as has been suggested. I agree with Chris and would suggest that the existing definitions she cites also be included as additional, specific criteria. Kirk Leonard
2. Most English speakers understand "wildlife"to be animals (or insects... things that move), not plants, and certainly not soil organisms, a major component of biodiversity. Kirk Leonard
   • The term "species", from a scientific point of view, designs any living organism, whatever the phylum. All these terms will be clearly explained so that popular thoughts do not confuse people about the principles.
3. In order to be applicable in the short term, the priority areas included in standards must have already been delineated and mapped. Most of the world has not yet been mapped for HVCAs. We propose adopting identified conservation priority areas that have been identified and mapped (such as AZE sites and KBAs, which have been identified for many hotspots). Chris Dragisic
   • As stated in the proposal for new draft principles, HCV is to be taken as a concept rather than an official mapping, which would certainly prove too restricted at the principle level. This concept looks flexible enough to evolve through time and to include every scientifically sound mapping, such as those mentioned by Chris. By choosing between this or that classification system at the principle level, we would risk to be fixed in time and restricted to this system, whereas we could be tempted to add some more areas later.
4. Focusing production on degraded lands, wherever possible, will reduce pressure both on natural habitats and on food supply.Chris Dragisic
   • This is absolutely relevant and this type of recommendations is precisely what we expect to be formulated as criteria or indicators to achieve the high conservation values principle, if accepted.
5. By establishing a cut-off date for eligibility (similar to those used for the Voluntary Carbon Standard or the Clean Development Mechanism), we can ensure that land is not cleared specifically to benefit from RSB recognition or incentives. Chris Dragisic
   • The temporal aspect is not easy to bring into the discussion but we must indeed find a mean to avoid the kind of practice mentioned by Chris. This would need the consultation of field experts with experience in this aspect.
   • This is really critical in order to insure that the demand for fiber that meets the standards does not inadvertently create pressure to convert ecosystems in advance of applying the standards. Obviously, we don’t want producers claiming they meet the standard for no conversion – even though they cleared it 3 months ago – on the basis that they aren’t clearing now. The date selected by systems is generally the date of the adoption of the P&C, but in the interest of maintaining some consistency across standards in the marketplace, we might want to select 2005 as a cut-off date (the date that RSPO has adopted).Debbie Hammel
6. A focus on perennial crops, where possible, will further reduce the environmental impacts associated with planting and harvesting, and help increase carbon storage, soil retention, etc. Chris Dragisic
   • This brings the question of a general principle regarding agricultural best practices, as it is the case for the RSPO and in the RTFO report (but at the criteria level only). This aspect can be discussed in the next teleconference (7th September).
7. Conversion of native habitat. I am still concerned that this principle will allow the conversion of native ecosystems to produce biofuel feedstock. Not all native ecosystems will be captured by an HCV analysis, and a provision that production also not endanger (directly or indirectly) wildlife species may not prevent conversion either.Debbie Hammel
   • If you refer to the definition of HCV2 (Globally, regionally or nationally significant large landscape-level areas where viable populations of most if not all naturally occurring species exist in natural patterns of distribution and abundance. ), native ecosystems can be included in this category. But there will be a consequent need to define what significant means at the global, regional and national levels, depending on the other occurences of the ecosystem in question somewhere else on earth.

Biofuel production should not directly or indirectly degrade or damage soils

Biofuel production should not directly or indirectly contaminate or deplete water resources

1. It is a common knowledge that biofuel production ( ref: ethanol production from sugarcane molasses)is highly polluting as far as water and air pollution is concerned. Thus the principle should be formulated as - Biofuel production should improve its social and environmental performance by adopting environmentally sound technologies and strictly conform to national regulations for prevention of water pollution. Jayant Sarnaik

Biofuel production should not directly or indirectly lead to air pollution

1. Biofuel production will always lead to a degree of air pollution, either in the production process (which I understand is referred to in this principle) as exhaust gases from the crop growing stage (tractors, dryers, haulers, etc.), or ultimately in the fuel consumption process from consumers (cars/trucks/buses/ships exhaust gases). "Biofuel production should not directly or indirectly increase levels of air pollution" or similar could be a suggestion. Hugo Hays
   • This is relevant and actually true for all the principles. It has been decided to have aspirational principles, which state how things should ideally be "in a perfect situation". This must be taken as the ultimate, yet idealistic objective to achieve, which would represents the highest level of sustainability that can be reached. At the criteria and indicators level, the approach will be more realistic and, as any human activity has an impact on environment, considered through a relative point of view (notions of progress or improvement as compared to another situation for example).
   • I agree with Hugo. Human activity causes pollution, no way around that. No “increased” or “reduced” pollution have got to be the goals. I would support a positive statement of “reducing” pollution. It seems to me the GHG group analysis will necessarily be focused on the marginal impacts of biofuels. A principle of no air pollution is not only unrealistic, it is not credible. Kirk Leonard
   • We did discuss phrasing some of the principles in a more positive way. With reference to the Water, Soil and Air pollution principles, could we not consider "(water, soil, air) quality must be maintained or improved" (as in the Cramer principles). This acknowledges that pollution will occur, but remains aspirational. Ruaraidh Petre --RP 17:04, 5 September 2007 (CEST)

The use of biotechnologies for biofuels production should improve their social and/or environmental performance, and always be consistent with national or international biosafety protocols

1. Why retain the "social and/or environmental performance" phrase in the biotechnology environmental principle category?Social is covered in the social category.Kirk Leonard
   • After reformulating, we were tempted to add the social aspect, because as a principle, we have to remind that biotechs can represent a benefit for people too. It is likely that we will eventually remove it unless we finally decide to give biotech a separate category.