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O C C A S I O N A L P A P E R

Manuel R. Guariguata

Omar R. Masera

Francis X. Johnson

Graham von Maltitz

Neil Bird

Patricia Tella

Ren Martnez-Bravo

A review of environmental issues inthe context of biofuel sustainabilityframeworks

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A review of environmental issues inthe context of biofuel sustainabilityframeworks

OCCASIONAL PAPER 69

Manuel R. GuariguataCIFOR

Omar R. MaseraUniversidad Nacional Autnoma de Mxico

Francis X. JohnsonStockholm Environment Institute

Graham von MaltitzCouncil on Scientifc and Industrial Research

Neil BirdJoanneum Research

Patricia Tella

Stockholm Environment Institute

Ren Martnez-BravoUniversidad Nacional Autnoma de Mxico

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Occasional Paper 69

2011 Center or International Forestry ResearchAll rights reserved

978-602-8693-62-2

Guariguata, M.R., Masera, O.R., Johnson, F.X., von Maltitz, G., Bird, N., Tella, P. and Martnez-Bravo, R. 2011 A reviewo environmental issues in the context o biouel sustainability rameworks. Occasional Paper 69. CIFOR, Bogor,Indonesia.

Cover photo World Wide Fund or Nature Deutschland (www.ww.de/living-planet-report)

This report has been produced with nancial assistance rom the European Union, under the project Bioenergy,sustainability and trade-os: Can we avoid deorestation while promoting bioenergy? The objective o theproject is to contribute to sustainable bioenergy development that benets local people in developing countries,minimises negative impacts on local environments and rural livelihoods, and contributes to global climate changemitigation. The project will achieve this by producing and communicating policy-relevant analyses that caninorm government, corporate and civil society decision making related to bioenergy development and its eectson orests and livelihoods. The project is managed by the Center or International Forestry Research (CIFOR) andimplemented in collaboration with the Council on Scientic and Industrial Research (South Arica), Joanneum

Research (Austria), the Universidad Nacional Autnoma de Mxico and the Stockholm Environment Institute. Theviews expressed herein can in no way be taken to reect the ofcial opinion o the European Union.

CIFORJl. CIFOR, Situ GedeBogor Barat 16115Indonesia

T +62 (251) 8622-622F +62 (251) 8622-100E [email protected]

www.cior.org

Any views expressed in this publication are those o the authors. They do not necessarily represent the views oCIFOR, the authors institutions or the nancial sponsors o this publication.

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Table of contents

Abbreviations v

Executive summary vi

1 Introduction 1

2 Overview of biofuel sustainability frameworks 32.1 European Union Renewable Energy Directive 52.2 Roundtable on Sustainable Biouels 62.3 Roundtable on Sustainable Palm Oil 62.4 Round able on Responsible Soy Association 72.5 Better Sugarcane Initiative 72.6 Forest Stewardship Council 7

3 Environmental issues in sustainability frameworks 93.1 Biodiversity, soil, water and environmental impacts 93.2 Land use change (direct and indirect) and associated greenhouse gas emissions 103.3 Main limitations o the rameworks 12

4 Improving biofuel sustainability frameworks: Key issues and challenges 174.1 Integration and harmonisation 174.2 Moving beyond principles, criteria and indicators 194.3 Limitations o principles, criteria and indicators 19

5 Conclusions 23

6 References 25

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Tables

1 A broad typology o biouel sustainability rameworks and certication schemesby governance level and adoption requirements 3

2 Environmental issues in the six biouel sustainability rameworks 10

3 Compatibility o criteria on land use change and greenhouse gas emissions insustainability rameworks (assessed against EU RED) 13

Box

1 Proposals or a uniorm (minimum) set o biouel standards 18

List of tables and boxes

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BSI Better Sugarcane Initiative

EC European Commission

EU RED European Union Renewable Energy Directive

FSC Forest Stewardship Council

GA General Agreement on aris and rade

GHG Greenhouse gas

HCV High conservation value

IPCC Intergovernmental Panel on Climate Change

ISO International Organization or Standardization

LUC Land use change

NGO Nongovernmental organisation

PCI Principles, criteria and indicators

RSB Roundtable on Sustainable BiouelsRSPO Roundtable on Sustainable Palm Oil

RRS Round able on Responsible Soy Association

WO World rade Organization

Abbreviations

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With the rapid growth o biouel production andconsumption, and the prolieration o policy decisionssupporting this expansion, concerns about thebiouel sectors environmental and social impactsare increasing. Consequently, a range o actors among them governments, multilateral institutions,nongovernmental organisations and multistakeholderindustry groups have created sustainability

rameworks, some mandatory, others voluntary. Tisreport examines how the most developed sustainabilityrameworks or eedstock production (includingbiouels) address key environmental issues. It identiescritical gaps in these rameworks and proposes areasor improvement. Te rameworks analysed are theEuropean Union Renewable Energy Directive (EURED), Roundtable on Sustainable Biouels (RSB),Roundtable on Sustainable Palm Oil (RSPO), Roundable on Responsible Soy Association (RRS), Better

Sugarcane Initiative (BSI) and the Forest StewardshipCouncil (FSC).

Te key ndings o the report are as ollows:

Te rameworks share broad sustainabilityprinciples. However, they dier greatly in terms otheir comprehensiveness and how they apply specicindicators or environmental issues, particularly withrespect to land use change (both direct and indirect),allocation o degraded land or eedstock cultivation,and related accounting o greenhouse gas emissions.

Tere are unresolved conicts regarding the bestoptions or implementing sustainability concerns:through gradual, improvement-based certicationsystems (e.g. International Organization orStandardization [ISO]) vs. criteria and indicatorapproaches; harmonised global sustainabilityrameworks vs. specic rameworks; and mandatoryvs. market-based schemes.

Such conicts and possible trade impacts arise inpart because o the lack o documented practical

experience, as biouel sustainability rameworks havebeen implemented only recently. Further eorts maybe required to systematically document progress intheir implementation. Designing tiered approachesto compliance may provide room or middle ground

Executive summary

so that some aspects can be tackled throughadherence to strict standards (related or exampleto habitat conversion) while other aspects can besystematically improved over time.

It is not yet clear which o the rameworkswould best ensure minimal impacts rom landuse change, including allocation o degradedland or eedstock cultivation and guidance onbest management practices. Similarly, no clearconsensus exists on which criteria and indicatorsshould be included in all circumstances or whichsustainability ramework should become theglobal or international standard. Any globalstandard may, however, be less eective and/or lessdesirable compared to regional standards.

Avoiding indirect land use change will be almostimpossible to control solely through project-level certication o good practice. Enhancing

productivity in the agricultural sector could helpto reduce indirect land use change, especially inregions where production levels are currently lowby international standards. Te application ointegrated approaches to land use planning thatconsider biodiversity issues as well as agriculturalpractices with biodiversity considerations mayalso be necessary. National policies shouldalso be developed to encourage eective landuse planning and application o agriculturalbest practice.

In the absence o sucient hard data with whichto gauge the eectiveness o existing sustainabilityrameworks, the report notes that the standardso these rameworks are not sucient to mitigatethe eects o direct and indirect land use changeand promote environmental conservation. A keyrecommendation, thereore, is that such standardsshould be complemented by other policy instruments.Furthermore, as sustainability rameworks are only a

means to an end, they must be supported by practicalguidance, eective interpretation o standards,principles and criteria, and development o veriableindicators, along with the provision o appropriatetools, approaches and capacity building activities.

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Introduction

1

With the rapid growth o biouelproduction and consumption, andthe prolieration o policy decisions

supporting this expansion, especially in Brazil,the EU and USA, concerns about the long-termsustainability o biouel development are increasing.In particular, the USA and EU have set targetsor renewable energy to constitute 20% and 10%,respectively, o all transport uel by 2020 targetsthat will require large amounts o biouel. Tis

raises questions about the easibility o biouelproduction and its associated environmental, socialand economic impacts.

Some authors argue that the global demand oragro-industrial expansion, including bioueleedstocks, is likely to be met partly at the expenseo intact and/or undisturbed orest mostly acrossthe tropics, rather than permanent croplandareas (Gibbs et al. 2010). Another topic odebate is whether there is sucient degraded or

otherwise available land to support such expansion(Schoneveld 2010).

Although analysing the sustainability o biouelproduction began as an academic exercise, it isbecoming a mandatory requirement or producersthat seek to enter international markets suchas the EU. Te issue is also aecting importsin some consumer countries. In recent years,several initiatives, some mandatory, others

voluntary, have been introduced and rameworksdeveloped, by various governments, multilateralinstitutions, nongovernmental organisations(NGOs) and certication bodies. Among theseare regulatory rameworks created by the EU,

Germany, the Netherlands, the UK and the USA.Other relevant initiatives are those concerningthe voluntary adoption o sustainable productionstandards linked to the implementation ocertication schemes.

Sustainability as it applies to biouel production,transport and consumption has not beenunanimously dened. However, a common, coreconcept is that sustainable production can ensure

the continued productive capacity o the naturalresources on which it is based, is economicallyeasible and is socially and environmentallyacceptable. In this regard, standards andcertication schemes that cover the entire liecycleo biouels (e.g. production, processing andtransport) are considered viable strategies to ensurethe sector adheres to principles o sustainabledevelopment. In particular, several standardsaddressing sustainable production o bioenergy orbiouel eedstocks include principles and criteria

designed to preserve biological diversity andecosystem integrity, to reduce greenhouse gas(GHG) emissions and mitigate the eects o landuse change (LUC), as uncontrolled expansion obioenergy eedstocks may diminish the provision oecosystem services.

Te extent to which biouel sustainabilityrameworks address these issues and incorporatevalidated perormance indicators is the ocus o

this report. Not all the sustainability rameworksexamined here relate directly to biouel production(as most eedstocks have other uses or ood andbre), but they have direct implications or thedebate on biouel sustainability. Te term biouel

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2 | M.R. Guariguata, O.R. Masera, F.X. Johnson, G. von Maltitz, , N. Bird, P. Tella and R. Martnez-Bravo

sustainability ramework should thereore beinterpreted in this light. Furthermore, sustainabilityrameworks are at dierent stages o developmentand implementation, and many o them are

incipient. Consequently, there is little guidanceon how to assess the eectiveness o sustainabilityrameworks, particularly rom an environmentalperspective. Te report also identies critical gapsin the rameworks analysed and proposes areas orimprovement, with a ocus on the implications oapplying biouel standards that reduce the risk odeorestation.

Te rameworks under review were selectedaccording to their overall relevance in the

context o large-scale cultivation o eedstocksacross the world (sugarcane, oil palm, soybeans,woody biomass) and their global importance ininuencing production, consumption and tradebetween producing and importing countries and/orregions. Te rameworks analysed in this report are:

European Union Renewable Energy Directive(EU RED)

Roundtable on Sustainable Biouels (RSB)

Roundtable on Sustainable Palm Oil (RSPO)

Round able on Responsible Soy Association(RRS)

Better Sugarcane Initiative (BSI)

Forest Stewardship Council (FSC)

With the exception o the EU RED, theserameworks are voluntary certication schemes inwhich certied operators agree to a set o principlesand guidelines. For large-volume commoditiessuch as palm oil, soybean and sugarcane allo which are used as biouel eedstock andare considered in this report roundtablesinvolving a range o stakeholders along theproduction chain (government, NGOs, industry,

importers, exporters) have been established. TeFSC is somewhat dierent in that it certies theperormance o a orestry operation and is notconcerned with eedstocks or biouels per se;however, the expected commercial use o woodyeedstocks or second generation biouels impliesits uture relevance. Te ollowing section sets outthe background and context o the six sustainabilityrameworks analysed in this report and thenprovides a detailed description o each ramework.

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Overview of biofuel sustainabilityframeworks2

Governments across the world have issuedlaws, regulations and decrees related tobiouel production and consumption,

many o which contain concepts and provisionsaddressing sustainability. However, some lawsdo little more than simply mention genericsustainability principles or considerations, whereasothers incorporate a systematic and continuouseort to improve sustainability rameworks.Tere are also dierences in the way biouel

sustainability rameworks are implemented andenorced, whether through national legislation in

the producing country, through voluntary adoptionor through a combination o both (able 1).Such dierences and particular combinations oapproaches may determine specic outcomes roma governance standpoint (Cashore et al. 2010). Tisreport analyses two broad approaches in the contexto sustainability rameworks, across the two-dimensional continuum depicted in able 1.

Te rst approach, involving mandatory

implementation, assumes that biouel production,processing and transport are matters o public

Table 1. A broad typology o biouel sustainability rameworks and certifcation schemes by

governance level and adoption requirements

Governance level Voluntary Mandatory

International RSBRSPORTRS

BSIFSC

Supranational/regional EU RED

National Nordic EcolabelVeried Sustainable Ethanol Label(SEKAB, Sweden)

Renewable Transport Fuel Obligation (UK)German Biouel Quota Act (Germany)Swiss Petroleum Tax Act (Switzerland)

BSI = Better Sugarcane Initiative, EU RED = European Union Renewable Energy Directive, FSC = Forest Stewardship Council, RSB= Roundtable on Sustainable Biouels, RSPO = Roundtable on Sustainable Palm Oil, RTRS = Round Table on Responsible SoyAssociation

Note: The six sustainability rameworks examined in this report are RSB, RSPO, RTRS, BSI, FSC and EU RED. Others are included

or reerence. It should be noted that the only mandatory aspects in the EU RED relate to accounting rules or greenhousegas emissions and other requirements such as no-go areas. In addition, the EU RED can be implemented through bilateralagreements, voluntary certication schemes or national requirements.

Source: Typology adapted rom Schubert and Blasch (2010)

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interest and, as such, must be managed by the state.In such cases, national laws or executive authoritiesempower regulatory bodies to establish criteria andstandards on the sustainability o biouels, to issue

norms and quotas, and to veriy the registration oproducers and industrial acilities. Tis is, in short,a national legislative approach to implementingand monitoring sustainability rameworks, withthe government bearing the associated costs, andthe countrys ability to carry it out depending on itscapacity or monitoring and law enorcement. Inthe context o producer and consumer countries,this approach may be implemented throughbilateral agreements.

Te second approach assumes that biouelproduction, processing and transport can bemanaged through market-based schemes linkedto voluntary adoption o dened productionstandards and accompanying certication. Forcertication, an independent party evaluates theproduction process against a set o predeterminedstandards. A key eature o this approach is thatthe producer is responsible or covering costsand proving compliance; thereore, the producer

decides whether to comply and with whichstandard. Even i a certain market, or example theEU, sets mandatory sustainability standards, theproducer can choose to sell to a dierent marketwith no such requirements.1

A possible third approach is a combination olegislative and voluntary market-based approaches,in which governments may set national mandatorystandards or biouel sustainability and requireproducers to comply via third-party certication.

O the six rameworks analysed in this report, onlythe FSC standard is not strictly related to bioueleedstock production, processing and trade. Te EURED and RSB have a strict biouel ocus, whereasthe others have a commodity-specic ocus (palmoil, soybean, sugar or timber) addressing theood, bre and biouel applications o the crop.In contrast to the biouel rameworks, the FSC iswell established, with a long history o project-level applications, which means it is useul or

1 In the case o the EU market, the producer can even sellto the EU, but it will not count towards the renewable energytargets established in the EU RED.

comparison. Te FSC standard is also consideredrelevant in this context because o its potential toserve as a ramework or certiying the productiono second generation biouels rom short-rotation

tree plantations. How the FSC ramework isultimately applied may largely depend on whetherit can be adapted to comply with essential criteriasuch as minimum liecycle GHG reductions andissues o LUC, aspects that are underdeveloped inthe current version o the standard.2

Other certication systems have been developedor the agriculture sector but they are not related tobiouel production per se (however, some lessonsdrawn rom these could help to advance sustainable

biouel production in the uture). For instance,EUREPGAP, a partnership between producer andretailer associations, ocuses on good agriculturalpractices, quality management, minimisation onegative environmental impacts o crop productionand track-and-trace control. Te SustainableAgriculture Network (SAN) was ormed byconservation groups, mostly NGOs, to promote thesocial sustainability o products that are sae andhealthy or the consumer, and are obtained in an

environmentally sustainable way. Te InternationalFederation o Organic Agriculture Movements(IFOAM) works on promoting the adoption oagricultural sustainability standards based onorganic production. Also not included here arethe eight environmental indicators o the GlobalBioenergy Partnership (GBEP) which are largelyintended to guide decision making on a genericlevel and which are considered a work in progress.3Tese are briey discussed however, in the contexto eorts to develop uniorm sustainability

standards (Section 4.1).

2 Other orest-based sustainability rameworks, which are notanalysed in this report, include the Finnish Forest CerticationSystem (FFCS), Chiles CERFOR and Brazils CERIFOR. Inaddition, the expansion o national orest certication systemshas led to the creation o the Programme or the Endorsemento Forest Certication (PEFC) or the assessment and mutualrecognition o national orest certication schemes; the PEFCnow covers more than 20 national schemes.3 http://www.globalbioenergy.org/leadmin/user_upload/gbep/docs/2011_events/11th_F_Sustainability_Stockholm_15-17_March_2011/indicators/names_and_descriptions.pd.

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A review o environmental issues in the context o biouel sustainability rameworks | 5

2.1 European Union RenewableEnergy Directive

Te European Union 2009 Renewable EnergyDirective (EU RED)4 sets an overall EU target

or renewable energy o 20% o total energyconsumption by 2020. Tis translates into bindingnational targets or member states, with eachmember state required to achieve individualnational targets or renewable energy. In addition,all member states must achieve a renewableenergy target o 10% o the transport sector. Inthis context, renewable energy includes not onlybiouels but also biogas and electricity derivedrom sources certied as renewable, includingsolid biomass, wind, solar and hydropower. Fora biouel to count towards these targets, it mustcomply with the EUs sustainability requirements.5In particular, to comply with the EU RED, rawmaterials or biouels must not have been cultivatedon primary orests and other wooded land, areasdesignated or the protection o rare, threatenedor endangered ecosystems or species, or highlybiodiverse grassland. Furthermore, to be eligible,biouels must not be made using material extractedrom peatland or land with a high carbon stock,

such as wetlands, continuously orested areas andland covered by trees taller than 5 m with a canopycover o 1030%.

In 2010, the EC adopted a package o twocommunications and one decision, with theollowing main points:6

4 Directive 2009/28/EC o the European Parliament ando the Council o 23 April 2009 on the promotion o the

use o energy rom renewable sources and amending andsubsequently repealing Directives 2001/77/EC and 2003/30/EC. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:140:0016:0062:EN:PDF.5 Te EU RED is unique in that its sustainabilityrequirements can be met through bilateral agreements withproducer nations and hence can be based on national ratherthan project-level principles.6 Te Communication on voluntary schemes and deault

values in the EU biouels and bioliquids sustainability scheme,the Communication on the practical implementationo the EU biouels and bioliquids sustainability schemeand on counting rules or biouels and the Decision onguidelines or the calculation o land carbon stocks areavailable at http://ec.europa.eu/energy/renewables/biouels/sustainability_criteria_en.htm. See also http://europa.eu/rapid/pressReleasesAction.do?reerence=MEMO/10/247&ormat=HML&aged=0&language=EN&guiLanguage=en.

Sustainable biouel certifcates. Te EC encouragesindustry, governments and NGOs to set upvoluntary schemes to certiy biouel sustainability.Te communication explains the standards required

to gain EU recognition. One o the main criteria orcertication schemes is that they have independentauditors, which evaluate the entire productionchain, rom the armer to the conversion acilities,to the trader, to the uel supplier that delivers petrolor diesel to the lling station. Te communicationsets standards requiring this auditing to be reliableand raud resistant.

Protection o undisturbed natural areas. Tecommunication highlights that biouels should not

be made rom raw materials rom tropical orests orrecently deorested areas, drained peatland, wetlandor highly biodiverse areas. It also sets out guidelinesor assessing whether this is the case. It explicitlyprohibits the conversion o orest or oil palmplantations.

Promotion only o biouels with high GHG

savings. Te communication reiterates thatmember states must meet binding national targets

or renewable energy, and that only biouels withhigh GHG savings can count towards the nationaltargets. It explains how to calculate such savings.o be eligible, biouels must deliver GHG savingso at least 35% compared with ossil uels, risingto 50% in 2017 and to 60%, or biouels rom newprocessing acilities, in 2018.

Tere are three ways o complying with the EURED: 1) provide evidence o compliance with thenational system o the member state where the

biouels are being used; 2) reer to a voluntaryscheme that has been approved by the EuropeanCommission or 3) meet the terms o a bilateral ormultilateral agreement approved by the EC. Forcriteria related to GHG emissions, data shouldinclude evidence o compliance with member stateprocedures or application o the deault valuesin the EU RED. Economic operators must usethe mass balance system to prove that eedstocksor biouels were sourced in a way that meets thecriteria. Under this system, the share o material

that is certied as sustainable is tied to therespective shares o the nal products made romthe raw materials. Te mass balance system is less

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stringent than identity preservation, in whichcertied eedstock materials must be physicallyisolated rom noncertied eedstocks. However, themass balance system used in the EU RED is more

stringent than the book and claim system, whichis used elsewhere or renewable energy quotas andGHG emissions trading. Sustainability certicatesare generated or the certied eedstock; these canthen be sold to any biouel producers that wishto use these eedstocks. Te EC, recognising thatthe mass balance system is more complex andexpensive than the book and claim system, hasadvised that it will reconsider the requirement touse mass balance in its next report in 2012.

2.2 Roundtable on SustainableBiofuels

Te Roundtable on Sustainable Biouels (RSB)was established in 2007 to develop internationalsustainability standards through dialogue betweenconservation and development organisations, theprivate sector and academia. It is the only biouelstandard that covers the entire value chain, romarm to end user. Version two o the RSB standardsets out 12 principles and associated criteria or

sustainable biouel production along with guidanceand compliance indicators.7 Te 12 principles andcriteria address: 1) legality; 2) planning, monitoringand continuous improvement; 3) greenhouse gasemissions; 4) human and labour rights; 5) ruraland social development; 6) local ood security;7) conservation; 8) soil; 9) water; 10) air; 11) useo technology, inputs and management o waste;and 12) land rights. Te RSB has also developedguidance or conducting an environmental

and social impact assessment, including socialguidelines, ecosystem and conservation values,and soil and water guidelines. wo approaches arebeing examined to address indirect impacts: 1) theuse o an indirect LUC actor and 2) promotiono practices and eedstocks that lower the risk oindirect negative impacts.

In 2010, the RSB developed a GHG accountingmethodology that draws on the IntergovernmentalPanel on Climate Change (IPCC) guidelines. It

reers to the use o co-products, residues andwaste and may include indirect LUC. Te RSB has

7 Available at http://rsb.ep.ch/page-24929-en.html.

set a minimum GHG emission threshold o 50%or biouel blends compared with the ossil uelbaseline; this threshold will be increased over time.Te standard also requires each biouel in the blend

to have lower liecycle GHG emissions than thebaseline.

Te RSB has adopted a meta-standard approachto certication.8 Te RSB biouel certicationstandard is expected to become ully operationalin 2011. Te RSB has developed a standard or EUmarket access, which in July 2011 was adopted asa way to demonstrate and document compliancewith the EU RED.

2.3 Roundtable on SustainablePalm Oil

Te Roundtable on Sustainable Palm Oil (RSPO) isa global, multistakeholder initiative that promotesthe production and use o sustainable palm oilproducts.9 Te RSPO principles and criteria wereadopted at the end o 2007 and ocus primarily onthe agricultural or eedstock production side (i.e.they do not ully cover transport and processing).A methodology and set o guidelines are available

or national interpretation o the RSPO principlesand criteria. Te RSPO principles are based on: 1)commitment to transparency; 2) compliance withapplicable laws and regulations; 3) commitmentto long-term economic and nancial viability; 4)use o best practices by growers and millers; 5)environmental responsibility and conservation onatural resources and biodiversity; 6) responsibleconsideration o employees, individuals andcommunities; 7) responsible development o new

plantings; and 8) commitment to continuousimprovement in key areas. Te RSPO intends toprepare a common ramework or reporting, as wellas a methodology or the certication o emissionreductions. It will propose methods to reduce GHGemissions, particularly related to LUC, includingplanting on degraded land, increasing yield andinvestigating ways to reduce emissions rompeatlands.

8 A meta-standard denes what is considered sustainable

through principles and criteria; however, compliance requirescertication under existing standards, which in turn ensurethat the principles and criteria o the meta-standard arecomplied with.9 http://www.rspo.org/.

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2.4 Round Table on Responsible SoyAssociation

Te Round able on Responsible Soy Association(RRS) was established in 2006.10 Te RRS

standard was released in 2010 and containsve principles: 1) legal compliance and goodbusiness practice; 2) responsible labourconditions; 3) responsible community relations;4) environmental responsibility; and 5) goodagricultural practice. Tese principles ormthe oundations or norms to be used withina voluntary certication system or soybeanproduction. Certication in each country isbased on national interpretation o the principlesand criteria, built on the Guidance or NationalInterpretation developed by the RRS. Nationalinterpretations o the RRS generic standard deneapplicable local indicators, guidelines or proceduresor economic, social and environmental aspectsadapted to local circumstances. Te RRS is alsoexpected to develop national-level maps that willprovide biodiversity inormation, as well as asystem to guide responsible expansion o certiedsoya. A voluntary RRS certication scheme willbe developed in compliance with the EU RED.

Operational procedures are yet to be developed orthe supply chain certication and the supply chaintraceability scheme.

2.5 Better Sugarcane Initiative

Te Better Sugarcane Initiative (BSI or Bonsucro)sustainability rameworkincludes principles andcriteria or sustainable sugarcane production andthe Chain o Custody Standard.11 Te BSI standardincludes a set o technical and administrative

requirements or tracking along the entire supplychain or all sugarcane products. Te BSI standardincludes the ollowing principles: 1) obey the law;2) respect human rights and labour standards;3) manage input, production and processingeciencies to enhance sustainability; 4) activelymanage biodiversity and ecosystem services; and5) commit to continuous improvement in key areaso the business.

Te BSI has proposed a scheme or calculating

GHG emissions rom sugarcane cultivation,

10 http://www.responsiblesoy.org/.11 http://www.bonsucro.com/.

processing to sugar and/or ethanol, and directLUC. Emissions released rom indirect LUC are notincluded, as the methods and data requirementsare not available. Deault and secondary data

(dened as being generated rom other sources) areproposed or calculating emissions where actualdata are not available.

Te BSI has also developed guidance documentsor certication, including recommendations onthe interpretation o the principles and criteria andthe requirements to ensure compliance. As withmany other schemes, the BSI recently submitted anapplication to the EU or recognition as a voluntaryscheme; i granted, this will allow sugarcane

ethanol importers in the EU to use the BSI to showcompliance with the EU RED rom 2011 onwards.

2.6 Forest Stewardship Council

Te Forest Stewardship Council (FSC) is anindependent, nongovernment and non-protinternational organisation ounded in 1993 toglobally promote sustainable orest managementthat is environmentally appropriate, sociallybenecial and economically viable.12 Te members

o the FSC make up a general assembly, whichserves as its highest decision making body; it has atripartite structure covering social, environmentaland economic aspects (chambers).

Te FSC developed a global sustainabilityramework or its denition o well managedorests; the ramework includes 10 principles and56 criteria related to: 1) compliance with applicablelaws and international treaties; 2) long-term tenureand use rights and responsibilities; 3) indigenouspeoples rights; 4) social well-being and respector workers rights; 5) equitable benet sharing;6) reduction o environmental impact; 7) orestmanagement plans; 8) monitoring and assessment;9) maintenance o high conservation value orests;and 10) tree plantations. Tese principles andcriteria are tailored to conditions in dierentcountries.

Using the FSC label requires chain o custody

certication, which involves tracking orestproducts all along the supply chain and

12 http://www.sc.org/.
http://www.responsiblesoy.org/http://www.bonsucro.com/http://www.fsc.org/http://www.fsc.org/http://www.bonsucro.com/http://www.responsiblesoy.org/

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guaranteeing that products meet specic contentrequirements. Audits are conducted by independentcertication bodies. As woody biomass is likely tobecome a eedstock with the development o second

generation biouels, the FSC scheme remains validor woody biomass production and it may gainurther relevance. O special relevance or thebiouel sector is FSC Principle 10 on establishmento tree plantations; however, the FSC does not yethave a specic policy on woody biomass used orbiouels.

Whereas the other sustainability rameworksanalysed in this report are all quite new, the FSCwas established almost 20 years ago. Tereore,

a substantial amount o inormation on itsperormance and eectiveness is available (see Auldet al. 2008 and reerences therein). Te area o FSC

certied orests is about 140 million ha, across 82countries; although primarily in temperate andboreal latitudes, nearly 9 million ha is located intropical countries. Nevertheless, FSC certication

has reportedly made only a modest contributionto reducing deorestation at the global level sincethe rst FSC certicate was issued about 15 yearsago (Marx and Cuypers 2010). It should be noted,however, that the FSC standard was not explicitlydesigned to halt deorestation at the countrylevel. It has also been shown that certication isofen unattainable or small and medium-sizedenterprises in developing countries, as these cannotmeet the high costs involved (Auld et al. 2008). TeFSC is thereore contemplating group certication

and certication o small-scale and low intensityorest operations, designed to overcome suchnancial and technical constraints.

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Environmental issues insustainability frameworks3

Sections 3.1 and 3.2 provide a comparisono the rameworks in terms o keyenvironmental issues: biodiversity, soil,

water and environmental impacts, and LUC andrelated GHG emissions. ables 2 and 3 provide anoverview o the main comparisons, which orm thebasis or the more detailed analysis in Section 3.3 oidentied gaps.

3.1 Biodiversity, soil, water and

environmental impactsBiouel production, transport and consumptionhas been challenged over its possible negativeimpacts on soil and water conservation, air quality,biodiversity, and on GHG emissions rom directand indirect LUC. All six rameworks examinedin this report include criteria related to areas withsignicant biodiversity that are not under ocialprotection. Most o the rameworks also includecriteria related either to the need to protect orrestore native ecosystems in order to reduce theimpacts o the conversion o orest or naturalhabitat in order to cultivate biouel eedstocks. Allrameworks emphasise the conservation o areaso signicant biodiversity value as well as nativeecosystems and natural habitats wherever possible(able 2). Furthermore, all rameworks prohibitconversion o high conservation value (HCV)areas or biouel eedstock production. Te RSPOconsiders HCV areas as no go, while the FSC,RRS, BSI and RSB authorise limited exploitation

o HCV areas so long as the HCV is maintained.

Te EU RED sustainability ramework requiresthat land with high biodiversity value (highly

biodiverse grasslands, primary orests and natureprotection areas) or high carbon stock (wetlands,peatland and orested areas that also harboursignicant biodiversity) is not used or biouelsand bioenergy production. For biomass eedstockproduced in the EU, the EU RED accepts the cross-compliance rules o the Common AgriculturalPolicy as providing assurance o compliance inrelation to environmental impacts on soil, waterand air (able 2). Te RRS plans to developnational-level biodiversity maps. Some rameworks(BSI, RRS, RSPO, RSB) reer to internationalconventions such as the Convention on Wetlands(Ramsar Convention), Convention on BiologicalDiversity, the Rotterdam Convention on pesticidesand industrial chemicals and the StockholmConvention on Persistent Organic Pollutants. Withthe exception o the EU RED and the FSC, all therameworks give due consideration to ecologicalconnectivity, which is an integral part o land useplanning or conservation purposes (see Section

3.3.1). In the context o second generation biouels,which could involve genetic manipulation o woodyplants or disease resistant plant traits or enhancedproduction o lignocellulose (Hetemki et al. 2010),the FSC prohibits the use o genetically modiedorganisms.

Te sustainability rameworks adopt dierentapproaches to addressing environmental impacts.Some require an environmental impact assessment,as dened by the relevant legislation in orce, or

good arming practices. For example, the RSBprovides guidance or conducting an environmentaland social impact assessment, including soil,water, social and land rights guidelines. Te RRS

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includes integrated crop management measuresand practices in soya production, and the BSIprovides guidance or setting up an environmentalmanagement plan. Te FSC requires an assessmento environmental impacts appropriate to thescale, management intensity and the uniqueness

o the aected resources including landscape-level considerations, as well as the impacts o on-site processing acilities. Issues related to accessto and management o resh water resourcesare underdeveloped in the reviewed standardsparticularly as they relate to competition or waterwith ood crops.

3.2 Land use change (direct andindirect) and associated greenhouse

gas emissionsTe potential conversion o large expanses o nativeorests or biouel plantations is a major concern inthe biouel debate. Tereore, assessing the extentto which biouel projects are causing deorestation,

or LUC, or seeking to reduce the risk odeorestation should be key goals in sustainabilityrameworks. LUC is particularly relevant becauseo its implications or the provision o numerousenvironmental benets such as biodiversity, soil andwater conservation and GHG emission reductions.

Assessing the LUC impacts o a specic biouelproject is not easy, particularly or indirect LUC,because o the lack o standard denitions odeorestation and even orests, the simultaneoususe o biouel eedstocks or ood, eed and/oruel and the geographical disconnect betweenwhere planting and deorestation occur, amongother actors (Gao et al. 2010). Te sustainabilityrameworks only address direct LUC, essentially bylimiting the type o land on which biouel projects

may be established.

Concerns about LUC and GHG emissions areclosely linked. For global GHG emission targetsto be met, biouels must make a signicant

Table 2. Environmental issues in the six biouel sustainability rameworks

EU RED RSB RSPO RTRS BSI FSC

Environmental impact assessment + + + + +

Good arming practices + + + + +Mitigation o indirect LUC or indirect impacts + +

Use o degraded lands + + + +

Conservation o unprotected areas o signicantbiodiversity value and HCV areas

+ + + + + +

Conservation o natural ecosystems + + + + + +

Ecological corridors, riparian areas + + + +

Genetically modied organisms + + + +

Conversion o orest/natural habitat + + + + + +

Soil management and soil protection + + + + +

Use o agrochemicals + + +

Use o waste and residues + + + + +

No burning during land clearing +

Conservation o above- and below-ground carbon + + + +

Calculation o GHG emissions rom direct LUC + + + + +

Calculation o GHG emissions rom indirect LUC

BSI = Better Sugarcane Initiative, EU RED = European Union Renewable Energy Directive, FSC = Forest Stewardship Council, GHG= greenhouse gas, HCV = high conservation value, LUC = land use change, RSB = Roundtable on Sustainable Biouels, RSPO =Roundtable on Sustainable Palm Oil, RTRS = Round Table on Responsible Soy Association

Note: + indicates that the issue is explicitly addressed (either with or without enough guidance or its implementation). indicates that the ramework contains little or no specic mention o the issue.

Source: Adapted rom Henneberg et al. (2010) and Scarlat and Dallemand (2011)

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contribution to reducing emissions, particularly byavoiding deorestation. Tis objective can be easilytranslated into criteria and quantitative indicatorsthat set out certain levels o emission reductions.13

For this reason, in most rameworks, deorestationis treated implicitly through statements on specictargets or GHG emission reductions, which inpractice imply that no LUC is involved. Below wereview in detail how each ramework treats LUCissues (see also able 3).

Te EU RED attempts to minimise emissions dueto direct LUC by restricting which types o landcan be used to produce biouel eedstocks. Landsthat cannot be used to produce biouels include 1)

primary orest and other wooded land (to protectbiodiversity and prevent carbon stock losses); 2)wetlands (which can have extremely high carbonstocks); 3) continuously orested areas, denedas land o more than 1 ha with trees taller than 5m and a canopy cover o more than 30%, or treesable to reach those thresholds in situ; and 4) lando more than 1 ha with trees taller than 5 m anda canopy cover o 1030%, or trees able to reachthose thresholds in situ, unless evidence is provided

that the amount o carbon stock o the area beoreand afer conversion ulls certain requirements(both (3) and (4) are included because carbonstock losses must be considered in GHG emissionestimates) (able 3).

Te RSB does not include a specic LUC criterion.However, its Principle 3 addresses GHG emissions,and states that (the RSB) liecycle assessmentmethodology should be used. Tis includesemissions due to stock changes in above- and

below-ground dead organic matter and soilorganic carbon rom conversion o natural ormanaged ecosystems to cropland or bioenergyeedstock production only, using an IPCC ier 1type approach. As such, the RSB methodology isnot designed or orests that remain orests (e.g.conversion o natural orest to oil palm plantation).Furthermore, the RSB methodology does notinclude indirect LUC. However, its Principle3b states that use o co-products, residues andwastes should be incentivised, a policy that could

ameliorate indirect LUC.

13 However, calculating GHG emissions requires the use oliecycle assessment, which has yet to be standardised.

Te RSPO Principles and Criteria or SustainablePalm Oil Production state that the RSPO willurgently establish a working group to considerall issues relating to Greenhouse Gas emissions,

in terms o their relevance to the oil palm sector .However, at the time o writing this report, theRSPO had not published any principles or criteriaspecically addressing GHG emissions. TeRSPO has not adopted the EU RED limitations onprevious land use, but has considered imposinglimitations on the average carbon stocks beoreconversion o land to oil palm plantations and theuse o osets to sequester carbon i development oplantations generates emissions (able 3).

Te RRS includes two criteria on GHG emissionsand expansion o soya production. Criterion4.3 mentions ossil uel use, soil protection andopportunities or increasing carbon sequestration.However, it does not set a value as the limit oGHG emissions. In the context o responsible soycultivation, Criterion 4.4 o the RRS states thatcultivation should not be expanded into nativeorest, according to its denition.14 However,land that was cleared beore May 2009 and had

been used or agriculture within the previous 12years can be used, unless native orest has beenre-established through regeneration. In addition,soya cultivation should not be expanded intonative vegetation.15 Tese conditions will limitthe amount o GHG emissions due to direct LUC.However, the values used to dene native orestare not aligned with the denition o orests in theUnited Nations Framework Convention on ClimateChange (UNFCCC).16 Tis could create a situationwhere soya cultivation could expand responsibly

into non-native orest but still cause deorestation.For example, while the RRS denes orests asareas with at least 35% crown cover and with atleast some trees o 10 m in height, the governmento Brazil has dened orests as containing trees o 5m in height and with 30% crown cover. Tereore,a parcel o land that has trees with these latter

14 Te RRS denes native orests as areas o nativevegetation o 1 ha or more with canopy cover o more than 35%and where some trees (at least 10 trees per hectare) reach 10 min height (or are able to reach these thresholds in situ [i.e. in

that soil/climate combination]).15 No denition o native vegetation is provided.16 Under the Kyoto Protocol countries must dene a orestas having canopy cover o 1030%, height o trees at maturity(in situ) o 25 m (or the ability to reach this height) and aminimum size o 0.051.00 ha.

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characteristics would be considered orest underthe Kyoto Protocol but could still be deorested orresponsible soya expansion (able 3).

Te BSI adopts the one mandatory criterion in theEU RED (to protect land with high biodiversityvalue, land with high carbon stock and peatlands)to control the production source o sugarcane.Te BSI also includes a non-mandatory criteriondedicated to GHG emissions. Criterion 3.2limits GHG emissions to a specied amount pertonne o sugar or amount per megajoule (MJ)o ethanol produced (24 g CO2-eq/MJ). Tis ismore stringent than the EU RED, but the EU REDlimit is mandatory. Te calculation method is the

same as that in the EU RED, which addresses onlyemissions rom direct LUC.

Te FSC does not address GHG emissions in itsstandard. However, FSC Principle 10 states that thedesign and layout o plantations should promotethe protection, restoration and conservation onatural orests, and not increase pressure on them.More specically, Criterion 10.6 says that diversityin the composition o plantations is preerred,

so as to enhance economic, ecological and socialstability. Tis runs counter to the establishment ohighly productive monospecic stands, typical obiouel operations. In addition, Criterion 10.9 statesthat plantations established in areas converted romnatural orests afer November 1994 normally shallnot qualiy or certication.

A comparison o the six sustainability rameworksreveals a lack o consensus on approaches tomitigating the impact o indirect LUC (able 2).

Four o the rameworks (EU RED, RSB, RRS,RSPO) specically mention the use o degradedlands or cultivation, and the EU RED gives apremium (doubling actor or the EU biouel quota)to biouel eedstocks produced on degraded landand also produced rom crop residues and wastes.However, although the rameworks seek to ensurethat bioenergy originates rom raw material with alow risk o leakage such as biomass cultivated onunused, degraded land or rom organic wastes andcrop residues no standard specically promotes

land use planning or cultivation on abandonedor degraded land in order to mitigate leakage.Where rameworks do include mitigation systems,

such systems are weak. Moreover, an operationaldenition o degradation has not been agreedupon at either national or international levels (FAO2009, Guariguata et al. 2009). For the purposes

o suitability o oil palm cultivation, degradedlands can be dened as those with low levels oabove ground carbon and biodiversity.17 None othe rameworks analysed here accounts or GHGemissions resulting rom indirect LUC.

3.3 Main limitations of theframeworks

3.3.1 Land use planning and bestmanagement practices

As the rameworks and their standards are onlya means to an end, they must be supported bypractical guidance, eective interpretation oprinciples and criteria, and the provision oappropriate tools and approaches. For example,although most o the rameworks examinedin this report reer to good arming practices,none explicitly addresses biodiversity issues inthe context o production landscapes. Practicesexplored in the eco-agriculture literature provide

many examples that can be adapted to any biouelproduction operation (Scherr and McNeely 2007)including agro-ecological zoning and/or economicincentives that are linked to specic land usepractices. As discussed above, even well-designedrameworks and their standards are not sucientalone to mitigate direct and particularly indirectLUC. Tereore, rameworks and certicationsystems need to be complemented by other policyinstruments (Hennenberg et al. 2010). Eectiveland use planning is potentially critical in this

regard. None o the rameworks analysed inthis report explicitly requires the developmento new, highly productive cultivation systems(which would minimise urther habitat landconversion). Should this issue be included in theuture, however, sustainability rameworks mayalso have to be explicit about whether geneticallymodied organisms (GMOs) are to be used. Teew rameworks analysed here that address the useGMOs are unclear in this regard.

17 For an example rom Indonesia, see http://www.wri.org/stories/2010/11/aq-indonesia-degraded-land-and-sustainable-palm-oil.

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3.3.2 Carbon stocks

Bioenergy stakeholders ofen misunderstand therelationship between sustainability, carbon stocksand GHG emissions. In the context o the above

discussion, sustainability means production thatensures continuity without causing a depletion onatural resources, soil or water, as measured againsta dened baseline. However, in the context oorests, the relationship between sustainability andcarbon stocks is not straightorward. It is possibleor two sustainably managed orests at the same site(and even with the same species) to have dierentcarbon stocks. Even though both managementsystems are sustainable, the transition betweensystems can cause a change in carbon stocksand CO2 emissions or sequestration during thetransition period. For example, increasing harvestrotations increases carbon stocks in the landscapewhile decreasing carbon in harvested woodproducts (Nabuurs et al. 2007). Tus, shorteningharvest rotations temporarily decreases carbonstocks in the landscape.

A specic example is the conversion o unmanagedorests to oil palm plantations (Bird et al. 2010).

Both the unmanaged orest and the oil palmplantation may be sustainable but the transitioncan cause a carbon stock loss o more than 100tonnes o carbon per hectare over more than 30years. During the transition period, the activityis temporarily unsustainable. It may thereore benecessary or biouel sustainability rameworksto include a criterion on the transition ocarbon stocks.

3.3.3 Spatial scales

Many environmental sustainability principlesand criteria are o limited eectiveness because othe exclusive ocus on the production unit at thearm level. However, it is possible that a certiedoperation using production practices that aresustainable at the arm level may cause some ormo harm or undesirable eects at landscape orregional levels, including the eects o indirectLUC. In essence, arm-level assessments do notconsider the cumulative eects o multiple arm-

level impacts. Tis is the case or the conservationo biodiversity, water resources and soils, orexample. In the case o water resources, the

appropriate ecological unit or assessing impactsis probably at the watershed scale. Where asustainability standard requires national legislation,applying land use planning decisions at the national

or local level that are mandated by nationallegislation can mitigate some impacts (in thiscontext the EU RED option o bilateral agreementsis highly relevant). Frameworks such as theRSPO and RRS have started to prepare nationalinterpretations o their principles and criteria toensure the implementation o certication at thecountry level, according to specic conditions.

Furthermore, threshold levels that are useul and/or acceptable at the arm level can be insucient

or inadequate at larger scales. A good exampleis the Brazilian Forest Code, which states that inbiomes other than cerrado and Amazonian orest,native plant cover must be retained on 20% oevery property, although the remainder can beconverted to other land uses. I the principle olegality is applied in the strictest sense, this legalprovision is the only limit to LUC, thus allowingor the conversion o 80% o all lands, with sizableenvironmental impacts (e.g. on water cycle,biodiversity and soil conservation). Tus, a possibleconict exists between the principles o legality andenvironmental sustainability.

3.3.4 Temporal scales

Many ecological processes, such as climate changeor soil degradation, occur over long periods.However, a 20-year span has been chosen in theEU RED and other rameworks as the standardtimerame or estimating (or discounting) thevarious possible impacts o biouel production.

Tis period was chosen on the assumption thateedstocks would come rom agricultural sources.Te main carbon stock in this case is soil organiccarbon, and the simplied IPCC methodology (ier1) or calculating carbon stock changes rom LUCassumes a 20-year transition period. Te transitionperiod will be shorter or tropical situationsand longer or temperate or boreal ecosystems.However, changes in land management and use,particularly involving orests, cause carbon stock

changes that occur over longer periods. It has beensuggested that a more appropriate timescale orestimation or sustainable orest systems is the rstrotation (Bird et al. 2010).

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3.3.5 Compliance in the context of weaklocal capacity

A major limitation o the sustainability rameworksanalysed in this report is that their implementation

in developing countries is dicult becauseo dierences in goals, local capabilities andcertication costs. In terms o goals, the EU REDstandard aims especially at avoiding LUC andensuring climate mitigation a goal that, accordingto the UNFCCC, is considered an obligationo the developed world because o historicalGHG emissions. Similarly, most rameworkspromote GHG emissions savings, which, althoughimportant, are not the responsibility o developingcountries. Developing countries, however, are

actively pursuing biouel production becauseo the sectors potential contribution to ruraland socioeconomic development and may bedicult or these countries to ully comply withenvironmental standards including those o theEU RED.

Local capabilities (e.g. to eectively monitorcompliance) could also aect developing countriesability to meet the complex requirements o the

voluntary schemes or the EU RED. Consequently,institutional weaknesses may prevent developingcountries rom exploiting their comparativeadvantage in biouel production, which ariseslargely rom avourable tropical climates andrelatively low labour costs. Te high biomassproductivity in tropical and subtropical climatesallows or a better energy balance and lower GHGemissions with respect to temperate latitudes (ElBassam 2010) as in the case o sugarcane andethanol production in Brazil (Smeets et al. 2006).

More importantly, some least developed countries(LDCs) are viewed as risky locations with respectto ullling or enorcing biouel sustainability

rameworks. Domestic and international investorsmay perceive LDCs as unlikely to gain access tothe EU market, and thus will not even considerthem or investment, despite their high production

potential and competitiveness (Johnson 2011).

Te costs o biouel sustainability certicationshould not necessarily become a barrierper se;they have been estimated at less than 0.5 euro/tonne o carbon (EC 2008) or approximately 0.001euro/litre. However, these estimated costs arebased on European conditions, whereas the costsin developing countries would likely be muchhigher, particularly compared with local incomes.Furthermore, biouel certication processes

would impose high transaction costs because othe lower administrative and technical capacitiesin developing countries and because o weakinstitutional capacity.

Te bioethanol produced in Brazil is an example oa biouel that easily satises the EU RED criteria.However, Brazils bioethanol industry was initiallydeveloped to achieve policy goals related toenergy security, import substitution and economic

development. Climate change mitigation andenvironmental quality improvements (includingair) were added later as an extra benet (Macedo2005). Te constraints imposed on developingcountries by most o the sustainability rameworksanalysed in this report suggest that somecomplementary measures will be needed to betterassess key environmentdevelopment linkagesand thus exploit synergies and avoid conicts. Inother words, greater eort is needed in the contexto global and regional policy to insure that the

development impacts o biouel production areweighed alongside climate impacts.

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Improving biofuel sustainabilityframeworks: Key issues andchallenges4

4.1 Integration and harmonisation

As this review demonstrates, biouel sustainabilityrameworks have very dierent ormulationso environmental criteria and denitions (e.g.regarding the areas to be protected). However,views dier as to whether a globally harmonisedsustainability ramework would be broadlyapplicable or appropriate. On the one hand is theargument that in an era o global trade, the globalmarket will inevitably induce the ull emergence

o international rameworks and/or certicationsystems (Scarlat and Dallemand 2011). Kaditi(2009) concludes that because specic rameworkstend to be misused and misinterpreted, aninternational certication standard is perhapsthe only instrument that could make a dierence.Schubert and Blasch (2010) urther point outthat only an international, legally binding biouelsustainability standard will prevent exportingcountries rom diverting their bioenergy exports to

countries that have weak or non-existent minimumimport standards, with the associated negativeenvironmental consequences.

On the other hand, Mol (2007) argues thatharmonisation, standardisation, certication andglobalisation o biouel pathways may end upempowering the largest and better organised actors,or avour developed countries at the expense odeveloping countries. Developed countries havehistorically been deorested and, in the context

o agricultural expansion alone, their agriculturalland area has decreased substantially over theyears (Gibbs et al. 2010). Tis means they areless strongly bound by their own deorestation

concerns. In addition, the cost o certicationtends to be lower in developed countries (includingFSC certication see Marx and Cuypers 2010),which already possess the necessary technical andtechnological capabilities to undertake the morestringent production practices.

Buchholz et al. (2009) urther add that a single xedset o sustainability criteria and indicators mightnot be advisable or bioenergy systems; rather,

they advocate or exible biouel sustainabilityassessments that can be adapted to dierentspatial and temporal scales. Hennenberg et al.(2010) also believe that it would be naive to thinkthat biouel sustainability rameworks could (orshould) adopt a uniorm set o criteria because eachstandard seems to serve at a specic stage o theproduction chain and or a particular eedstock.Although van Dam et al. (2008) caution againstallowing biouel sustainability rameworks toprolierate, they nevertheless argue that attemptsto develop a global certication system may inact lead to complications because o dierencesbetween regions in terms o production systems,spatial scale, socioeconomic settings and degreeso environmental sensitivity and conservationvalue. NGOs and civil society may be betterequipped to assess whether greater complianceis achieved through a global standard or throughmany separate rameworks. Regional approaches tobiouel certication may in act be more appropriate

than either national or global approaches as theymay have greater economic exibility than nationalschemes while incorporating regional developmentobjectives (see Section 4.2). In any case, how a

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Box 1. Proposals or a uniorm (minimum) set o biouel standards

From Schubert and Blasch (2010):

Reduction in liecycle greenhouse gas emissions;

Avoidance o indirect land use change;

Prohibition o use o biomass eedstock cultivated on land with high carbon stocks;

Maintenance o soil quality and ertility through reduced use o agrochemicals;

Conservation o orest ecosystems;

Sustainable management o water resources;

Control o use o genetically modied organisms; Compliance with basic social standards.

From Fritsche et al. (2011):

Sustainable resource use (land use efciency, secondary resource use efciency);

Biodiversity (conservation o land with high biodiversity value, biodiversity-riendly agricultural practices);

Climate protection (liecycle greenhouse gas emissions rom direct and indirect land use change);

Soil quality (avoidance o erosion, maintenance o soil organic carbon);

Water use and quality (availability, use efciency, quality);

Airborne emissions (SO2, particulates);

Food security (availability and aordability o ood);

Social use o land (secure land access, land tenure);

Healthy livelihoods and labour conditions (adherence to International Labour Organization principles orlabour rights).

From the Global Bioenergy Partnershipa (2011):

Liecycle greenhouse gas emissions;

Soil quality;

Harvest levels o wood resources;

Emissions o non-greenhouse gas air pollutants;

Water use and efciency;

Water quality;

Biological diversity in the landscape;

Land use and land use change.

a These reer only to the environmental component. GBEP also considers another 16 provisional indicators covering both thesocial and economic dimensions.

global standard is to be crafed, i at all, remainsuncertain. Schubert and Blasch (2010) propose aminimum standard with eight components; theGlobal Bioenergy Partnership considers a set o 24

global sustainability indicators spread across theenvironmental, social and economic dimensionso biouel production, processing and transport(see Box 1).

Another potential restriction on developing a globalramework is the geographical concentration oexisting biouel industries based on agriculturaleedstocks. For example, the USA and Brazilaccount or a signicant percentage o theglobal ethanol output, and Brazil and India are

the worlds two largest sugarcane producers. Asimilar geographical imbalance exists or biodieselproduction, with Europe accounting or around75% o the total output (Solomon 2010). However,

the potential or trade surplus must also beconsidered, rather than just total output: Indiaand the USA are unlikely to ever have a surplus,whereas Brazil and other countries with highpotential and low population density can achieve asurplus o biouels or international trade (Johnson2011). Supranational initiatives such as the EURED may have ar-reaching implications becauseo their explicit reerence to imported biouels andrespective eedstocks rom suppliers anywhereacross the globe. o date, bilateral agreements

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between exporting and importing countries are thenorm (Schubert and Blasch 2010).

As is illustrated in Box 1, no clear consensus

has been reached regarding which criteria andindicators are critical and should be included orall circumstances, or which ramework shouldbecome the global or international standard. Aurther complication is that the leading bioueleedstocks clearly dier in their short- and long-term ecological impacts (Groom et al. 2008).Nevertheless, there is scope or developing a genericset o criteria, as some common key issues and/orindicators are emerging (Box 1). Ideally, standardswould remain exible with regard to geographical

origins, raw materials and conversion technologies,as well as the dierent levels o chemical inputsand soil degradation encountered in the contexto planting biouel crops on degraded lands. Asthe impacts o land expansion or uel and oodcrops are virtually indistinguishable rom eachother, it could also be argued that equal or uniormstandards should be applied or all agriculturalcommodities traded internationally. Nevertheless,harmonising biouel sustainability rameworks

is perhaps more likely to be achieved by movingaway rom the criteria and indicator approach andpromoting the adoption o international standardssuch as those o the International Organization orStandardization (ISO) (discussed in sections 4.2and 4.3).

4.2 Moving beyond principles, criteriaand indicators

Tat a set o principles, criteria and indicators

(PCI) has the power to drive sustainability inbiouel production, transport and processing isnot disputed. However, it is not the only solutionto all potential sustainability problems. We discussthis issue using the EU RED ramework andthe implications o certication schemes rom aEuropean perspective.

Te EU RED is a mandatory compliance schemeat the level o the importing (market) country. Tisis a very dierent concept rom a market-based

approach (such as the FSC), which targets nalconsumers. Tese two variants are by no meansthe only spheres in which PCI can be used to

drive sustainable biouel development. Individualproducer countries can develop their own countryspecic set o PCI, as in the case o Mozambique(Sapp 2010). In such cases, compliance with PCI

may be achieved through legislative processes, scalincentives or market-based incentives when appliedto local markets. For instance, the Brazilian socialseal, which requires that a proportion o eedstockcomes rom small-scale armers, triggers tax rebatesto reward compliance. Te Southern AricanDevelopment Community (SADC) has developeda set o principles or the SADC region.18Teseprinciples are more likely to unction as guidelinesor member countries than as mechanisms orpunishing bad or rewarding good practice. In

addition, companies can implement their own seto environmental standards against which they areexternally audited. Te ISO 14000 set o standardsis extensively used in the orestry industry or thispurpose (Scheppers 2010, Scarlat and Dallemand2011). A undamental principle o the ISOapproach is continuous improvement, in contrastto a PCI approach that usually seeks compliancerom the outset. However, the EU RED createsa unique environment or implementing a PCI

approach because it is an obligatory requirement orEuropean Union countries growing or importingbiouels intended to meet national blending targets.In many ways, a mandatory scheme should havegreater power to engender sustainability practices,but it could also have negative consequences interms o diverting unsustainable biouel productionto alternative uncertied markets (see 4.3.1)(Vis et al. 2008).

4.3 Limitations of principles, criteriaand indicators

4.3.1 Diversion to alternative markets

Preerential market access, even i it is notaccompanied by preerential price, is seen in theorestry industry as a key motivation or seekingcertication (Cashore et al. 2005). In the case oorestry certication, nal consumers create themarket pull by preerentially purchasing certiedproducts on a voluntary basis. Tis has been

sucient to prompt many orestry plantations toseek certication, and certied orests account

18 See http://www.probec.org/leuploads/04142010091932_SADC_Framework_or_Sustainable_Biouels.pd.

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or a large percentage o orests in some countries(Marx and Cuypers 2010). However, generally,certication has been sought or orests indeveloped countries and plantation orests rather

than or tropical orests (Cashore et al. 2005). Inaddition, large quantities o tropical hardwood aresold to countries that have a low level o demandor certication.

Many developing world biouel investors viewEurope as a major market or biouels. I alternativemarkets that are less concerned about sustainabilityissues develop, then non-compliant projects mightexport to these alternative markets. Te EUsobligatory certication might even encourage the

diversion o developing world biouels to othermarkets. Tis could occur at the country level, withonly some countries aiming to meet EU marketrequirements, or at the project level, where goodprojects get certied and the others seek alternativemarkets (Vis et al. 2008).

Maintaining certication is costly (Zarrilli andBurnett 2008) and so a slight price premiummight not be sucient to attract producers to the

certied markets. Producer country sustainabilityrameworks and joint agreements between the EUand producer countries are among the mechanismsto help alleviate this problem. It will, however,be necessary to rely on mechanisms other thancertication, such as national mandatory standards,to ensure compliance with criteria at the countrylevel rather than simply at the project level.Globally accepted rameworks and their standardsand a global requirement to adhere to these are twomechanisms or overcoming this potential obstacle.

An alternative mechanism would be or eachindividual country to ensure the compliance o allbiouels it produces.

4.3.2 Violation of free trade agreements

A subject o extensive debate is whether EU REDrameworks might violate some provisions o theWorld rade Organization (WO) (Zarrilli andBurnett 2008). Te General Agreement on arisand rade (GA) mandates equal treatment o

products that are the same in physical terms, thatis, like products. Sustainable and non-sustainablebiomass and biouels cannot be distinguished rom

a product or market perspective at the point o enduse, so the introduction o mandatory sustainabilitycriteria could be regarded as non-conormant (seeEchols 2009 and Vis et al. 2008). Tere is some

scope through GA or giving preerence toproducts that are more environmentally riendly;however, the sustainability criteria may also beconstrued as constituting echnical Barriers torade (B), which is potentially more problematic(Mitchell and ran 2010).

Te choice o implementation scheme or the EURED standard creates some additional concerns interms o WO consistency. Bilateral or multilateralagreements provide an option or addressing trade

conicts directly; as such, they are less likely topose a problem. However, the legality o voluntaryschemes used under the EU RED could bechallenged, as such schemes are considered privateand are not covered by international agreementsmade through the WO. Nearly all o the voluntaryschemes are associated with organisations basedin developed countries, mainly in Europe. At thesame time, biouels viewed as non-compliant withthese schemes are much more likely to come rom

(tropical) developing countries. Since this aectsthe sale o those non-compliant biouels, there is aninherent inconsistency with both the GA and theB agreements (Johnson 2011).

4.3.3. Creating compliance hurdles

Certication systems, as proposed in therameworks analysed in this report, set a minimumlevel that must be reached or certication tobe awarded. Tis approach runs the risk o theminimum standard being dicult or a badly runproject to achieve or even impossible to achievebecause o inability to meet a requirement suchas stating the actual date o deorestation. Tisproblem might arise more ofen in the orestrysector, in which projects usually run or severalyears, than in the biouel sector, in which projectsare largely being started aresh. However, irequirements are too stringent, especially in acountry with weak or even non-existent nationalrameworks, companies may opt or non-certied

production rather than certied production. In thissituation, an ISO approach, which incrementallyincreases environmental perormance, might

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prove more acceptable to the industry than anapproach that demands ull PCI compliance romthe beginning. However, an ISO approach maynot be easible or certain aspects where a more

stringent or else minimum threshold may be needed(e.g. prohibiting orest conversion). Tus a tieredapproach, where some standards should be applieduniormly, while others can be improved over time,may be an option.

As already mentioned, the cost o certicationis a concern and is likely to be disproportionallyhigher or developing countries than or developedcountries. Tis could be seen as giving developedcountries an unair advantage in biouel production.

Moreover, there is evidence rom orestrycertication (FSC) that the cost may be higher orsmall-scale producers than or large-scale producers(Pattberg 2006, Zarrilli and Burnett 2008). Tiscould discourage small-scale eedstock productionmodels, despite their potential to better support thedevelopment ambitions o developing countries. Inaddition, developing countries tend not to have theinrastructure or certication. Tis could createa major barrier to small-scale arming models in

developing countries and hence undermine thedevelopment potential o biouels in developingcountries.

4.3.4 Leakage

Probably the biggest shortcoming o market-basedinstruments involving certication via PCI is thatthey target individual producers, rather than the

entire sector (in this sense, the EU-RED bilateralagreement option is advantageous). Hence, thisapproach ails to take into account macro-levelimpacts, including what is ofen termed leakage.In the case o biouels, there are two key areaso concern regarding potential leakage: indirectLUC and impacts on ood security (Vis et al. 2008,Zarrilli and Burnett 2008). None o the rameworksinvestigated here eectively tackles indirect LUC.In addition, several indirect socioeconomiceects, such as increased land prices, rural orurban poverty, displacements and migration (bothtowards and away rom biouel developments)and diminished access to resources, are dicult toquantiy and link causally to a specic development.Te issue o indirect deorestation is o particularconcern as it may oset positive GHG benets rombiouels and hence nulliy one o the key reasonsor European support o biouel production.Accounting or indirect deorestation is dicult or even impossible to monitor through project-

level certication (Bird et al. 2010).

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Conclusions

5

As Raghu et al. (2011) put it, the emergingbiouel economy is likely to result inthe single largest reconguration o the

agricultural landscape since the advent o industrialagriculture. In theory, it is the aim o biouelsustainability rameworks to ensure that suchreconguration takes place with due considerationo environmental impacts and conservation oorests and other natural ecosystems that providecritical services to human populations. Tat said,

the ollowing points emerge rom this review: Although the rameworks share broad overall

sustainability goals, principles and criteria, theydier greatly in terms o their coverage andhow they apply specic indicators (and developveriable indicators) or assessment o theenvironmental impacts o biouel productionand related accounting o greenhouse gasemissions.

It is not yet clear which o the rameworks

analysed here would best ensure minimalimpacts rom land use change (both direct andindirect), including allocation o degradedland or eedstock cultivation. In particular,none o the standards specically promotes landuse planning or cultivation on abandoned ordegraded land to mitigate leakage. Guidance onhow to operationalise land degradation or thepurposes o biouel cultivation is also lacking.Attempts at operationalising degradationshould include at least a carbon component

(while not disregarding biodiversity and socialconcerns).

Issues related to access to and management oresh water resources are underdeveloped in thereviewed standards as they relate to competitionwith ood crops or water. As in the case ogreenhouse gas emissions, there appears to beno consistency in accounting or water ootprintestimates. It may be necessary to considergroundwater, irrigation, transpiration and watercycles, depending on the type o crop and itswater use eciencies. Te use o catchment-

level integrated water resource management isone mechanism to ensure that equitable waterallocations saeguard strategic water uses.

Tere are unresolved issues regarding thebest options or implementing sustainabilityconcerns: through gradual, improvement-basedcertication systems (e.g. ISO) vs. criteriaand indicator approaches; harmonised globalsustainability rameworks vs. eedstock specicrameworks; or mandatory vs. market-based orvoluntary schemes. Tese conicts arise partlybecause o the lack o documented practicalexperience, as existing biouel sustainabilityrameworks have been implemented onlyrecently and urther eorts will be requiredto systematically document progress duringimplementation. Designing tiered approachesto compliance may provide room or middleground, so that some aspects can be tackledthrough adherence to strict standards(related or example to habitat conversion)

while compliance o other aspects can besystematically improved over time.

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principles and criteria, and provision oappropriate tools, approaches and capacitybuilding activities. Biouel sustainabilityrameworks, whether mandatory or voluntary,

may not be enough to mitigate the impactso direct and indirect land use change, andso should be complemented by other policyinstruments particularly at the national level.

Avoiding indirect land use change will be almostimpossible to control solely through project-level certication o good practice. Additionally,enhancing productivity in the agricultural sectorcould help to reduce indirect land use change,especially in regions where production levels arecurrently low by international standards. Teapplication o integrated approaches to land useplanning that consider biodiversity aspects aswell as agricultural practices where biodiversityissues are inserted may also be needed. Nationalpolicies should also be developed to encourageeective land use planning and application oagricultural best practice. Te eco-agricultureliterature explores many practices that can beadapted to any biouel production operation,including agro-ecological zoning.

Te temporal nature o emissions ollowing landmanagement changes requires that or short-term reductions in greenhouse gas emissions,a greater emphasis must be placed on biomassthat would either be quickly regrown or elsequickly decompose. Te ormer drives bioenergydevelopment to crop-derived biomass and theresulting potential or indirect land use change.Te second type o biomass is less prone toindirect land use change but depending on theintensity o extraction may negatively aectnutrient cycles and long-term sustainability.Tese points are ofen not addressed insustainability rameworks and may need urtherdevelopment.

No clear consensus exists on which criteriaand indicators are so critical as to be includedin all circumstances or which sustainabilityramework should become the global or

international standard. Te Global BioenergyPartnerships list o global indicators is the mostrobust and inclusive o the main dimensions obiouel production, processing and transport,generated through stakeholder consensus.From the standpoint o operationalisation andspecic guidance, however, the Roundtable onSustainable Biouels ramework has broaderapplicability and exibility.

Any global standard may be less eectiveand/or less desirable compared to regionalstandards, which can be better tuned to the levelo economic development and the particularclimatic and physical circumstances, while at thesame time oering greater economic exibilityand administrative savings than a collection onational schemes.

Sustainability rameworks derived romroundtables such as the RSPO may needto develop real monitoring and enorcingcapabilities or else partner with an organisation

that has such capacities (see Laurance et al.2010). In this respect, the FSC can serve asa model or those roundtables with clearstakeholder imbalances, such as the RSPO andother pro-industry groups.

In the absence o sucient hard data with whichto gauge the eectiveness o existing sustainabilityrameworks in mitigating the impacts o directand indirect land use change and in promoting

environmental conservation, the ollowingrecommendations or improvement are oered:

As sustainability rameworks are only a meansto an end, they must be supported by practicalguidance, eective interpretation o standards,

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