Searching for Sustainability - WWF · Presentation - WWF Germany Jenny Walther-Thoss . Topics ... ISCC and NTA 8080 do not define any requirements on this crucial point, or only contain

Searching for Sustainability

Comparative analysis of certification systems for biomass for the processing of Biofuels

Presentation - WWF Germany

Jenny Walther-Thoss

Topics Aim of the benchmark

Methodology CAT Tool Consultation of standard owners and internal (WWF) Experts

Results Summary of results Results per standard

Recommendations Revision of Standards Revision of EU RED Approval Process

2 WWF Presentation I Comparative Analysis of Biofuels certification schemes

Aim Point out analysis standards’ strengths and weaknesses

Discuss recommendations for the revision process of EU-RED and the approval process

Go through recommendations for standard owners

Give guidance to economic operators and governmental organizations about the quality of RED requirements


Methodology


A Compare the standard

P&C with CAT criteria in a desk study

B Consultations with scheme owners &

internal WWF experts

C Categorization of

standards

ISCC EU International Sustainability and Carbon Certification

Bonsucro EU Bonsucro - Standard for Sustainable Sugarcane Production

RTRS EU RED Roundtable on Responsible Soy EU RED

RSB EU RED Roundtable of Sustainable Biomaterials EU RED

2BSvs Biomass Biofuels Voluntary System

RSPO RED Roundtable on Sustainable Palm Oil RED

NTA 8080 NTA8080

REDcert REDcert

SQC Scottish Quality Farm Assured Combinable Crops System

Red Tractor Red Tractor Farm Assurance Combinable Crops & Sugar Beet System

RBSA Abengoa RED Bioenergy Sustainability Assurance

Greenergy

Greenergy Brazilian Bioethanol verification programme

Ensus Ensus voluntary System under RED for Ensus bioethanol production

Compared schemes


Pillar A – CAT Tool

CAT is a formalised way to evaluate and compare voluntary standards

and certification schemes and allow comparisons (Food, Feed &

Bioenergie).

CAT asks questions and has a scoring methodology to assess the

strategic, structural, social, and environmental strengths and

weaknesses of standards and certification schemes against the WWF

requirements on a sustainability certification scheme.


CAT Tool Requirements

23 criteria in the part governance and organization

29 criteria in the part environment (including 5 EU RED criteria)

15 criteria in the part social

The CAT is a desk-based exercise that is based on criteria and processes defined in a scheme’s documentation. As such the CAT assessments contained in this study do not evaluate how a given scheme’s requirements are implemented in practice.


Pillar B – consultation process

Step 1:

Desk-Analysis of the public available documents of the standards done from PwC

Feedback round with the first draft to standard organization and including documents and information which are not public available (March & May 2013)

Step 2:

Feedback round with the second draft per calls and emails

Integration of feedback and internal discussion with WWF experts (May & June, September)

Phase 3:

Send around final results to all scheme owners – (mid Nov.)


Pillar C – Classification of Standards


Global National

Comprehensive criteria

RSPO RSB

RTRS Bonsucro

ISCC NTA8080

Greenergy

EU RED criteria

2BSvs RedCert RBSA Ensus

Red Tractor SQC

Multi - stakeholder Involvement

RSPO, RSB, RTRS, Bonsucro, ISCC, NTA8080

Greenergy

Pillar C – Categorization Geographical scope

National: Standard applies to a specific country/region Global: Standard applies globally

Criteria coverage EU RED: Standard covers primarily EU RED mandatory requirements Comprehensive: Standard goes beyond EU RED and formulates a more

comprehensive criteria set

Multi-stakeholder Standards which are developed and maintained with multi-

Involvement stakeholder participation


Scoring “Green”: 100% cover CAT-Criteria

“Orange: Cat criteria is partly addressed

“Red”: cat criteria is not addressed or no information was found by PwC

“Gray”: criteria is not applicable


Assessment Results


Global National

RSPO

RTR

S

RSB

Bonsucro

ISCC

NTA 8080

Greenergy

EU RED Mass balance

EU RED ecological criteria

Minimum GHG reduction threshold

High Carbon Stock Areas

Cut-off date

Comprehensive criteria SYSTEM REQUIREMENTS


Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Standard development and operation Compliance with ISEAL’s Code of Good Practice A R F F R N N

Written commitment to reduce impacts Compliance with reg., nat., international laws Multi-stakeholder partic. in std. dev. process

Multi-stakeholder participation in standard system Scientific input

Results-oriented performance Transparency in public reporting

Comprehensive criteria SYSTEM REQUIREMENTS


Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Standard development and operation Transparency in communication of the standard

documents and process

National/regional adaptations for global schemes available

Complaint and appeal mechanisms (Grievance mechanism)

Regular standard review

Business model

No Partial certification

Comprehensive criteria Conformance requirements


Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Accreditation

Stakeholder consultation in certification

Training of auditors

Training opportunities for standard users

Audit frequency

Audit sample size

Sanctions for certifications Approval sanctions for certification bodies

Traceability system

Comprehensive criteria Environmental and social governance


Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Social and Environmental Management System (EMS)

Biodiversity and conservation Biodiversity assessment

Priority habitat conservation Set aside, wildlife corridors

Endangered species Invasive species

Genetically modified organisms & segregated supply chains



Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Water Riparian vegetation defined and restored

Water availability Water quality improved

Water use and efficiency Run off and leaching

Water



Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Soil Erosion prevention

Soil quality Crop Rotation/intercropping

Soil structure Topography

Soil



Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Agrochemicals Integrated Pest Management

Hazardous agrochemicals restriction Agrochemical and fertilizer application

Agrochemical and fertilizer documentation Agrochemical and fertilizer storage

Agrochemical and fertilizer disposal

Multi-stakeholder involvement Agrochemicals



Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Greenhouse gas emissions Greenhouse gas emissions reduction

Waste Management Waste management



Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Forced labour

Child labour Safe and healthy work conditions

Spraying of pesticides and health protection Grievance mechanisms for workers

Freedom of association

Social – labour



Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Working hours Remuneration

Disciplinary practices Discrimination

Social – labour



Global

RSP

O

RTR

S

RSB

Bons

ucro

ISC

C

NTA

808

0

2BSv

s

Social context and welfare

Land availability and rights

Grievance mechanisms for local communities

Cultural heritage

Food security

Social-surrounding communities

Key findings


The mandatory requirements of EU RED are written in the documents to a similar level by all of the recognized standards; however, there is a significant quality difference in the implementation and practices in the field (traceability rules).

Some EU-RED standards already go beyond the criteria specified by the EU and address social and deeper environmental issues, including water, soil and air.

The current mandatory minimum sustainability requirements prescribed in EU RED cannot ensure that biofuels used in the EU, whether they are produced nationally or are imported, are sustainable according to the key sustainability criteria that WWF advocates.

Key findings


Multi-stakeholder schemes i.e. those with the active involvement of different stakeholder groups on all levels of the scheme (standard setting, audits and management of the scheme) generally provide a higher level of environmental and social performance.

Important issues are poorly represented in most of the approved standards, a) implementation of social and environmental management systems b) handling of invasive species, c) limitations on the use of hazardous chemicals, d) waste and water management, e) segregation of supply chains in order to offer a non-GMO option…

Many standards do not adequately address transparency in public reporting, internal system governance, and audit scope and intensity

Positive Results


Stakeholder participation: Most multi-stakeholder schemes have a comprehensive set of criteria and provide documents and information about stakeholder participation in the (further) development and implementation of the standard. There are opportunities for improving transparency and documentation of the participation, processes and decision-making procedures. The aim is to ensure equal representation of all of the stakeholders (as in the case of RSPO, RSB, RTRS and Bonsucro, partly ISCC and Greenergy).

Audit frequency: On a positive note, audit frequency by certification bodies and sampling procedures are precisely defined by most of the standards (both multi-stakeholder and EU RED standards).

Complaint procedures and grievance mechanisms: On a basic level, all standards have requirements for dealing with complaints regarding the certification results. In comparison with the schemes focused on EU RED, the international multi-stakeholder schemes with comprehensive criteria have much stronger grievance processes for affected communities and other stakeholders.

Positive results – environment and social


All global acting standards beside 2BSvs have a clear

requirement for the protection of HCV areas which are more ambitious then RED-criterion.

Criteria in the point protection of soil and soil quality are comprehensive in most standards (RSPO, RTRS, RSB, ISCC, Bonsucro, NTA8080, Greenenergy)

Social criteria are implemented in the multi stakeholder standards likely (RSPO, RTRS, Bonsucro, ISCC, NTA 8080, Greenergy, RSB).

Critical results


Transparency in public reporting: Virtually all the schemes can improve their documentation and public reporting. In particular, schemes that concentrate on fulfilling EU RED criteria often lack publicly accessible audit summary reports, information on accreditation status (such as availability of accreditation reports) and approval sanctions for certification bodies. (e.g. in the case of REDcert, ISCC (in some areas), 2BSvs and others).

Accreditation: The standards use a very wide range of accreditation approaches, including by national accreditation bodies (ISCC and REDcert are accredited trough the BLE in Germany), via full or affiliate members of ISEAL (e.g. ASI), or merely by committing to comply with ISO standards. Only a few schemes require an independent accreditation process based on ISO standards with additional requirements for the respective standard (e.g. RSPO, RSB).

Impact assessment and monitoring the long-term effects of certification: With the exception of Bonsucro, nearly all schemes either have no monitoring and evaluation system or only a poorly developed one. They should also be capable of examining both the short-term and long-term effects of the standard.

Critical results – environmental & social


Restriction on the use of hazardous chemicals: Almost all standards have a general requirement for

reducing the most hazardous agrochemicals (World Health Organization (WHO) Classes 1A and 1B) as well as substances banned by the Stockholm and Rotterdam Conventions. In this context, standards focused on EU members, such as REDcert and Red Tractor, refer to good agricultural practice or European pesticide regulations. Some globally applicable standards such as 2BSvs, ISCC and NTA 8080 do not define any requirements on this crucial point, or only contain very cursory ones.

Separate value chains (chain of custody) for non-GMO materials: Only the RTRS certification scheme provides the option of using a separate chain of custody for non-genetically modified material.

Biodiversity and social criteria: With regard to meeting social and environmental requirements, the assessment results show clear differences between standards designed to comply solely with mandatory EU RED criteria and the more comprehensive global standards established as part of a multi-stakeholder scheme, which include all the end uses of the raw materials/feedstock (food and feed industry, etc.).

Recommendations

Standard owner

Approval process

EC

EU-RED Revision

Further recommen

dations


Recommendation for EU approval mechanism


The recognition and approval process should be more transparent, allow for stakeholder participation and include a grievance mechanism.

A monitoring system should be implemented in order to better monitor the effectiveness of the certifications, regardless of the scheme.

The EC should review, on a regular basis, whether the implementation practice of the standard complies with the legislation. The results of the review should be incorporated into the approval process.

Recommendation EU RED revision process


The EC should require a multi-stakeholder approach for all approved standards.

Requirements that are currently defined as voluntary or are only included as reporting obligations should be made mandatory.

Farm audits should generally only comprise on-site audits; remote audits should be not visible.

Group certification should be only permitted in a very strictly defined framework (smallholders, cooperatives) together with a required robust internal control system (ICS).

Further recommendations


A significant weak point with respect to implementing the legislation through voluntary standards is inadequate monitoring of the effectiveness of the certification and implementation on site. There is very little documentation on the effectiveness of the standards. From WWF’s viewpoint, the standards employed by the EU for implementing the legislation should provide evidence with regard to the implementation of binding sustainability criteria. Some of the multi-stakeholder standards have various mechanisms in place that should ensure sound implementation, but most of the standards developed specifically for the EU RED lack such checks and procedures.

As part of the revision of the EU RED, requirements that are currently voluntary or are only reporting obligations should now be made mandatory: social aspects, limitations on the use of hazardous chemicals, impact assessment and monitoring, mitigation of negative effects for environmental habitats, benefits for surrounding communities, analysis of the impact on food production.

www.wwf.de

© 2011, WWF. All photographs used in this presentation are copyright protected and courtesy of the WWF-Canon Global Photo Network and the respective photographers.

Vielen Dank!

Contact: Jenny Walther-Thoss WWF Germany [email protected] You can find the study and all results under:

http://wwf.panda.org/what_we_do/footprint/climate_carbon_energy/energy_solutions22/renewable_energy/bioenergy/

mailto:[email protected]





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Searching for Sustainability - WWF · Presentation - WWF Germany Jenny Walther-Thoss . Topics ... ISCC and NTA 8080 do not define any requirements on this crucial point, or only contain