Talk:RSB draft principle 9
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Principle 1
- Which are the international norms for land and water rights?
International norms can be more meaningful. National law can be weak. Two key international norms would be the CBD and the universal declaration of human rights. If a company has publicly committed to those norms, they should have a management system in place to check that these principles are being followed. Should be training its staff, have a confidential whistle blower policy.
ILO core conventions might be too difficult for most companies to commit to at this stage – might feel more comfortable to commit to decl. human rights. Worried that a public commitment that can’t be delivered on ILO core conventions. Seen very few biofuels producers who have been able to do this. Anonymous RSB
Principle 2
- GHG emissions declarations should comply with ISO 14025 standard and Life cycle assessment should be based on ISO 14040 series.
- Principle 2 requires that GHG emissions are lower than by use of fossil fuels.
- I suggest this is not strong enough for the following reasons:
- Question of land use change and deforestation are critical – better to separate out into a separate question. Avoid damaging or destroying land use sinks – might be worth separating these two points out.
- For biofuel crops grown on land that historically and originally consisted of forest the carbon of which has entered the atmosphere, this historic CO2 burden must be taken into account in calculating the GHG balance of those fuels. This is inclided in: "It should also include GHG emissions resulting from land use changes as land is converted to biofuel crop production."
- Brian Young, Imperium Renewables - The idea of determining the prior state of all land currently in agricultural production rotation is unnecessarily bureaucratic and does not contribute to the goals of developing sustainable biofuels. Much like the RSPO, a baseline date needs to be set upon which to begin the calculations of GHG reduction. Any new agricultural development will have to meet the principles and criteria as they are developed. Existing agricultural land should not be penalized for changes made to the land generations ago. For these sorts of processes to move forward, some reasonable acceptance of current realities must be established.
Principle 3
- This principle needs to address the fact that it is both the direct impacts of biomass crop growth and their potential displacement of existing food crops that could potentially impact on areas of high biodiversity. Furthermore,it should make reference to important areas of biodiversity and ecosystem services to address currently concerns regarding teh decline of ecosystem services.
- Specific reference to ecosystem services – overarching principle.
GMO rule
- These principles should be developed so as to be adopted internationally, without imposing practices of one country or region on other countries. The current form of the specific GMO principle is inappropriate in that light, as the intent is to require that GMO product use for biofuels require that the GMO product be labelled. While this may be practice in Europe, it is not in the United States. Thus, this principle breaks what I consider to be a foundational principle for the function of the Roundtable.
My recommendation is to eliminate the specific GMO principle, and to simply incorporate this under the first principle, which speaks to biomass production complying with all local and national laws. There should be no reason to specifically refer to GMOs, since this is merely one of many technologies that may be used in biomass production. For example, the use of any agricultural chemical would also require compliance with laws, and land use practices would similarly require compliance, and yet these are not singled out.
- It has been suggested that the GMOs are only a part of a wider chapter: biotechnologies. On both the positive and the negative aspects, not only must Genetically Modified Organisms be considered, but every other enzymatic or bacterial processes and every innovation to come in this field also. This is why it is proposed to replace the term GMs by the term biotechnologies, keeping the principle of precaution at its highest level.
- wondering about the practicality of this. Might be more palatable to have companies work towards full traceability. Argument as to whether this is a demand for labeling. Talking about ‘buyers making their own decisions’ implies labeling. Not necessarily going for a label here.
- Full traceability is virtually impossible to implement as continuous production processes will be unable to draw a clean line between feedstocks. It will also add undue compliance costs. My recommendation is that the traceability concept be condensed to a labelling requirement, but only for biofuels that are exported from their country of origin. As mentioned above, local and national laws may not require it, so why bother within country? A label showing country of origin and GMO status, (above or below an acceptable threshold), would allow countries with differing standards (or differing capabilities to enforce standards), to know enough to implement their own restrictions, should it be required. It would also allow shipments to be more readily traced as they bounce around the world market.
replace "areas of high biodiversity"
Some areas with low biodiversity can still be valuable from a conservationist point of view. Some valuable and threatened biomes are even characterized by low biodiversity. Therefore it seems more appropriate to refer to High Conservation Value Areas, as do the Cramer Principles on an indicator level. This may also serve as an incentive to identify these areas, making it more easy for companies to know which areas are off-limit for plantation development. I believe WWF is currently working on the identification of HCVA's.
Comment added by User:Sven Sielhorst on 6 June 2007.
Impact on Food security
User:Mathelaci stated on 18:47, 28 June 2007 in regards to the principle that that biofuels not displace food crops, "This is not an environmental impact!"
Definition needed for 'impairment of food security'. It is not necessary to safeguard excessive food consumption. We should look for possibilities of more efficient food production and more efficient diets (e.g. less or no meat).
Social issues
- Specific statement on labor standards – might be good to have a separate principle regarding this.
- Industry – commitment to work with governments and policy makers to reduce risk of food insecurity. Difficult to say when a company is specifically contributing to food insecurity – better to focus more on
Transparency and governance
Work towards traceability and transparency are an important principle. Companies have been bad at reporting what their position is about where they are and where they’re going – concerns about a backlash.
- See the comment about traceability above in the GMO rule section. Full traceability is very difficult to implement for continuous production processes. Recommendation is for labelling of all biofuels that are exported from country of origin.
Implementation - avoiding barriers to entry
- Wherever possible, existing environmental and quality assurance standards should be utilised so as to avoid additional beauracracy and costs for this emerging industry, as these are likely to be passed on to the consumer and be detrimental to their perception of this technology. These existing standards should be formally identified (or only where none exists, new standards agreed) as soon as possible with increasing levels of reporting and compliance over a period of, say, five years. Any system should reward full compliance to a greater degree and to an extent which is significantly greater than the cost of compliance so as to incentivise the supply chain adequately.
Equally, any comparison of carbon saving/emission levels between fossil and bioenergy systems should be based on similar lifecycle analysis methodologies.
- Important to know that companies have to be conducting env and social risk assessments and have systems in place to manage these risks. Good practice is still emerging, and companies will catch up with good practice as time goes on.
- Idea of an independent body to assess company progress. Independent subcommittee to look at companies’ progress. Already so many problems dealing with minimum audits, that concerns will be investigated appropriately.
Feel quite wary about the number of companies that can do certification credibly. Very difficult to know that a small producer is really following the rules. Might need a higher bar for large plantations.
- Dearth of thinking about the displacement effects, other tools.
- See the comment in the GMO Rule section regarding traceability. It's an implementation nightmare for continuous production processes. It would be much cheaper/easier to require a simple country of origin and GMO status label for all biofuel exported from its country of origin, rather than create a layer of beauracracy.
Biomass and social security within communities
On 13 July 2007, User:JonasVDB stated in regard to the suggested principle that biomass should promote social security within communities that: "Yes, biofuels must of course save the entire planet and make everybody rich, if not, they are 'unsustainable'. This criterion is clearly absurd."
Conversion of any native ecosystem
Why would we consider the conversion of any native ecosystem - HCV or not - to be sustainable? For example, clearing a tropical forest - regardless of its conservation value - will result in significant carbon emissions. In addition, continued clearing of native ecosystems will result in additional fragmentation at the landscape level, having unforseen impacts on species in adjacent areas. --Dhammel 23:53, 18 July 2007 (CEST)
German drafting principles on a national basis
During the telephone conference of the social Impact Working Group there was need to add German efforts to the UK and Netherlands criteria. Here is the latest on the German initiative to establish principles on a national basis as of mid-July 2007 Press Release in German --Ruddyconsult 18:13, 23 July 2007 (CEST)
Conserving native ecosystems
With regard to the statement about conserving native ecosystems, I think a more reasonable principle would look at preventing the systematic loss or impairment of ecological processes provided by native ecosystems. We are going to impact some land, but can we work to ensure biofuels do not result in ever increasing losses of natural systems. ( Kyle White)
Precautionary principle
Sebastien, you removed the Precautionary principle from Item 8. Why? I tried to improve the English, but am not satisfied with the results. Instead I must wonder *why* you removed the PP; I don't find a ref. to it anywhere else. Ruddyconsult
Comment on "lower" GHG emissions
The word ‘lower’ is not sufficiently specific. There should be a qualifier, either ‘substantially lower’ or a quantifiable target, eg. ‘at least 30% reduction’. This target could also be set in the criteria that will make this principle more concrete.
It is crucial to refer to the entire life cycle, using ‘well to wheel’ as the system boundaries as only a complete assessment will determine GHG reduction gains.
Taking into account, in the calculations, the land use changes and leakage is extremely important, but the text needs to be more specific in order to avoid loopholes. Alternatively, we might want to address these concerns through specific criteria.
