6

1.2 ‘right to use the land’ doesn’t seem to be the best indicator for criteria that mentions ‘clear land title’. [Suggest deciding whether you are looking for titles (ownership) or right to use the land. May be different – e.g. may be usufruct rights]

Clarify who can be the ‘independent authority’ mentioned in the notes. Can this be the auditors?

Include usufruct rights? (PR)
Need to define independent authority. (PR)
I agree these are distinct. Both should be included in criterion. (MG)
Land rights and land use rights:
Independent authority: The auditor shall verify the existence of the land title granted by the government agency If there have been some contestations, especially noted during the ESIA, then he/she shall establish the legitimacy of claim and demonstrability of rights.
The guidance on the approach to be used shall be detailed in the auditor’s manual. This can be inspired from the World Bank policies on how to deal with it. (MG)

9

What if national laws state that women cannot own land or what if national laws state that it is possible - but in customary practice it is not?
In addition there is often no documented evidence of ownership, especially in case of women.
Also protect non-owners (caretakers) of land being transformed in sugar plantations (e.g. women collecting fruits from forests or communally owned land).
Guidance: provide space for local level solutions on land ownership, access and use.

A detailed guidance shall be written in the auditor’s manual to verify these aspects. (MG)

10

A local legal representative would be needed to validate the document.

Agree (PT)
Agree (MG)

14

Point 1.2 - 'Independent authority' - Can it be a government agency or must it be an appointed agency? Will BSI provide a standard process to be followed?

Yes. (MG)
If there is a title, it shall be the official title in the country (e.g. notary, government agency or other): If this does not exist, or if it contested, then the process is as described in the lower part of the notes.
Guidance on such process can be found world Bank guidelines.(MG)

15

Good. Ensure prior informed consent is met with land used.

16

To include two additional clauses(indicators):
Records of no previous conflicts while acquiring land
Use of land for sugarcane cultivation does not diminish the customary/usufruct rights of local communities
Additional proofs, wherever there has been instances of conflicts, of conflict resolution mechanisms with fair/adequate compensation that have been agreed and adopted by all parties

OK (MG)

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2

The company can assume such responsibility for its employees, but it cannot control all of its suppliers’ employees.  It cannot be included as an indicator (eventually it could be a plus for a gold standard). In addition, for practical reasons, given the number of suppliers in this sector (especially in other countries), it would be an extremely hard for any mill to comply with such indicator.

The issue of contracted labour and control of the outsourcing is a very important. Some further discussion is needed on how best to capture the issue in an indicator. (MG)

3

It should be clarified here that 100% compliance with this criterion is required.  The wording is inconsistent enough that people might get confused and/or interpret it otherwise.  “Notes” should be revised as follows:  “Effective compliance may must be verified by sampling.  Guidance on what constitutes significant sampling - both by the operator and the certifier.

OK, agree (MG)

4

Do suppliers need to comply with all Human Rights standards in the BSI standard? Suggest criterion state exactly which Human Rights and labour standards suppliers must confirm they comply with. Otherwise open to variation.

Suppliers shall comply with those listed in the standard. (MG)

6

Unclear what this covers, ‘human rights and labour standards’ would benefit from further elaboration. The criterion is very broad and significant, but its single indicator is very limited. The criterion refers to ‘employees and workers including migrant, seasonal and other contract labour’ but the indicators are only about ‘suppliers and contractors’.
The ‘metric’ doesn’t work well here. For the other labour standards you have to comply (yes/no), but here you are looking for “100%” of all suppliers and contractors. Wouldn’t this also be clearer with a ‘yes/no’?. 
Notes:  Will compliance be verified by sampling or not? The word ‘may’ weakens this and suggests that it will not. Therefore this becomes a purely self-declaration. On the same page you have stated “self reporting is not a reliable source of information’ - So what value does this criterion have?

Agree that the single indicator does not adequately cover the criterion. (PR)
Contracted labour is a very controversial issue.

This is an indicator that has already triggered a lot of discussions within the social expert group. The human rights and labour standards are the same than those covered for all workers. Further discussion is needed. (MG)

Agree, the semantic needs to be reviewed in the entire document for consistency. (MG)

9

Guidance is needed on the fact that many migrant workers are women and have specific needs and problems. Auditors could make a needs assessments together with migrant women.
The policy shall include time for breastfeeding women and lighter/different tasks for pregnant women.
Equal access to medical assistance for men and women. Medical assistance shall include reproductive health care as well.
Guidance on ‘women’s rights’ specifically is needed.
'Sugar cane suppliers and producers should demonstrate compliance, through self-declaration'. Compliance verified by sampling. Comment: more effort is needed to show compliance and to verify it.
Note that overtime is often difficult for women as a result of their other tasks. The indicator should therefore pay specific attention to women’s reproductive roles and a safe return to home. Timely notification is certainly very important for women because they might have to arrange child care.
Add affordable and adequate housing for workers and their families.

The following could be added to the note for 2.2.
Compliance shall also include women and their specific needs.(MG)

11

Land tenure rights represent a big problem for large scale cultivation. E.g. in Mozambique lands are disaporpriated, leaving people without livelihood. No employ is created in return because sugarcane can only be produced economically using full mechanisation.

ESIA shall evaluate the impacts of new projects, including land rights. (MG)

15

How have the policies and rights been explained to the workers? Suggest that the indicator include a formal mechanism to explain rights and resolve disputes

I agree a mechanism to resolve disputes is important. BSI tries to measure the impact and not the process.  (MG)

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2.3.1 – Lost time accident frequency
The formula for the verifier should be clarified at the note: number of accidents x 1,000,000 / total men hours worked by month. Also, the definition of the “lost time accident” needs to be clarified to allow a proper analysis of the proposed value for the standard.

2.3.5 – Access to first aid
The indicator needs to be clarified for a correct analysis. It needs a definition for: “access to first aid” and “proximity”. For reference, in Brazil, the norm (NR-31) establishes the guidelines for agricultural activity.

H&S issues also covered by Laws and all Agricultural Chemicals usually covered in terms of the requirement that only “Registered Products” are used. Also required that label instructions be followed. In terms of Ag chemicals it should be completely sufficient if there is evidence of these two actions. (PT)
This “lost time” accident frequency number would still be a useful extra indicator but is more difficult to assess for agriculture and more appropriate for a mill (PT)
Lost time accident needs to be defined in Appendix 1 – any incident which results in a worker being booked off work. (PR)
Frequency rates are used across many industries / sectors, and calculate the number of accidents for a given number of man hours worked. Rates are calculated as number of accidents per million man hours worked.
Frequency rate = Number of Accidents x 1,000,000  Man Hours Worked
A frequency rate for Lost Time Accidents of less than 10 indicates good performance – best in class is a rate of about 1 and many significant companies achieve rates of well below 1. (MG)

More detail to be provided in guidance (MG)

3

What is really meant by the “visual check” regarding availability of potable drinking water?

The visual concerns the presence of water and the quantity. The quality cannot be relied upon visually (MG)

6

Lost time accident frequency. Auditors must not rely only on annotations in book. Must include confidential interviews with staff.
Does the verifier refer to number of incidents? Or number of hours? (need to reconcile with C3.1)
What about workers’ rights with respect to accidents?
The standard seems to be much more focused on the company efficiency. This should be a standard to improve working conditions (having efficiency as a result).
Appropriate protective equipment supplied.  Indicator implies ok to have just supplied it, even if they are not using it.  Notes here are stronger – but auditors audit against indicators not notes.
Training for H&S – is it realistic for 100% to be trained annually? Is it sufficient if you’ve been trained well before you start, even if you work for 3 years?
Number and expenses on training is not meaningful. The relevant outcome is to check what was learned/informed.
There is nothing specifically about H&S risk management.

Interviews with (all?) staff seem impractical (PR)
Verifier should state number of accidents. Or else define the whole concept in Appendix 1. (PR)
This criterion should apply to both milling and agriculture. Item 3.1 applies only to processing. (PR)
I suggest the verifier for Training for H&S should be “% staff trained/total labour force” (PR)
Just a thought wrt social issues – could the same questionnaire/audit sheet be completed by means of three interviews with employer, employee rep (random choice) and union rep? (PT)

Risk management was included initially but it was not included as a minimum, but was planned to be for the progress requirements. The reasoning being that all policies might not be there at the beginning while key areas can still be tackled. (MG)
We could put as the minimum the risk analysis, and have the comprehensive policies for the progress requirements. (MG)

9

Describe 'appropriate' personal protective equipment better.
Develop criteria, together with men and women, on what a safe environment means (guidance).
Availability of potable drinking water [in sufficient quantity] to each worker etc.
Add: particular attention should be paid to a safe and healthy workplace for pregnant and lactating women (including migrant workers, seasonal labourers and piece rate workers).
Guidance on reproductive rights is needed.
Guidance on gender sensitive monitoring of health and safety risks should be included.
Sufficient and good quality sanitary facilities, separate for men and women, should be available.
No mention of pesticides in the code. Add: Workers need to understand the health risks of direct contact with pesticides.
Make sure that the women are present at the meetings at which the health risks are explained.
Training on pesticide use to both men and women.
Minimize use of agrochemicals; always document the justification for their use; no preventive use; preference for narrow spectrum products.
Add: no use of pesticides by pregnant or breast-feeding women.

Appropriate refer to: effective protection against the risk it intends to protect, adequate given the working environment (e.g. work is performed in hot conditions), adequate in term of comfort of the workers, size of the equipment. (MG)
Agree that “sufficient” shall be added. (MG)
See above for the risk management approach. An approach for specific gender sensitive risks shall be included. (MG)

Pesticides are imbedded in the notes of training “in their operation”. Since it is the primary concern in H&S, we will make it clear. (MG)

The standard is not a best practice, but aims to measure the result. This is assumed via their potential impact, protection on the Health & Safety side, Impact on soil, air, water, biodiversity. (MG)  
Via Risk assessment - with pesticides being the main risk, adequate measure to mitigate risk would follow (ex. of such measures can be included in the guidance) (MG)

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10

This is not a very comprehensive list - fire precautions are missing and no mention of a medical centre with a doctor/nurse. This is one of the areas in which LeafTc has expertise.

It is not met to be comprehensive. By adding a risk assessment, this will allow focusing on major risks and measures are taken to mitigate the identified risks. (MG)

15

Indicator 1. Lost time accident frequency.  Comment – This is very difficult to get one specific metric, mechanical vs. manual harvesting changes the risk profile. Suggest the following, as well as an increase in the standard’s hours:
Suggest a risk assessment based on actual events and areas of high risk (e.g. cutting in field and aspects of mill operation. Training programs to educate workers of risk accompanied by standard operating procedures. Metric would be the number of workers trained in their respective jobs would be 100% and accident frequency, with demonstrated improvement over time.
    Indicator 2: Appropriate personal protective equipment supplied
Comment – Good. Should add that equipment should be available, especially spare equipment in case of worn equipment.
    Indicator 3: Training for health and safety. Comment – Good, but should also occur prior to assuming the job. Should be documented.
Indicator 4: Availability of potable drinking water.  Comment – How do you know it is potable and adequate supply?
Indicator 5: Access to first aid. Comment – Need to determine what first aid supplies (stretchers, band aids, and tourniquets) are available, and that supplies are current (e.g. no expired medications).
    Indicator 6: Number of trained first aid workers in each team of workers – Comment – This lacks definition of what a “team” is and there is no redundancy. What happens if the trained person is hurt, on vacation, or absent? In a mill, there should be clearly more than 1 in specific parts of the mill. Training should be documented and renewed annually through reputable certification entity.

Documentation to be held shall be provided as global summary for the standard. (MG)

16

Evidence of decent living quarters with good health, safety and environment measures. This may include,
Gender separated dormitories
Structures that provide adequate shelter,
Well lit buildings
Handrails in staircase
Fire safety equipments and emergency exits
Proper fire safety measures:
Properly labelled and mounted fire fighting and informative equipments
Emergency pathways and exits

These can be included in a more detailed guidance for suggested practices to mitigate risks identified (fire) or for H&S As such they would be part of a tool to assist for compliance to the standard. (MG)

17

2.3.1 Just to clarify, the assumed formula is number of accidents x 1.000.000 / men hours worked by month, right?
DG: That is how I read it.

Correct. But figure would apply over the whole reporting period, typically one year. (PR)
My understanding is:  number of accidents that result in some time loss per million man hours worked. “Lost time accident” needs definition. (PT)
Correct, by month for the whole reporting period. (MG)

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1

Jason Clay has been in print , and it was the basis of BSI having to withdraw our flyer at the  Durban ISSCT meeting, and I quote “that in some case the wages provided are not sufficient to replace calories burned in cutting sugar cane” I recall in Argentina the cane planters were only receiving US$1.00 per day, and they told us if they complained they would be replaced with machinery
I think there has to be a right to leave the job also, as most of the cane cutters in the poorer counties are indentured for the season.

Right to leave the job is part of the rights that workers shall be aware of. (MG)

2

2.4.2 – Ratio of cost of living to local minimum wage
This indicator does not measure the sustainability of a producer. Neither the local minimum wage (established by the government) nor the cost of living depends on the mill. The idea that the local minimum should cover cost of living is in the OIT C131 and, therefore, it is also included in the definition of the local minimal wage (indicator 2.4.1 already deals with that issue).
Standard suggestion: removing it.

I agree that this information does not depend fully on the company if a minimum wage has been defined in the country. Not all countries have defined a minimum wage. The indicator could be reformulated to include the lowest wage level by the company instead of minimum level. Computing the ratio with the local area cost of living enables a better appreciation of how wages in the area ensure people to live decently in the local area (local costing might differ widely from a national average figure). (MG)

4

Minimum wage and living wage are not always the same. Living wage is often higher than minimum wage.  Would be helpful to clarify whether living wage is a requirement of the standard or inspirational.  Can the notes recommend appropriate benchmarks for living wages?

Living wage and minimum wage are not the same. We do not require as such a living wage as there is not always consensus on the definition. Some recommendations on method for computing cost of living shall be provided. (MG)

6

‘local minimum wage’. Central to this criterion is who defines and calculates ‘cost of living’? the auditors? For each locality? For a family of what size? Potential for major problems in auditing this. Also what is ‘local’ here? Is it always the ‘national’ one? Is the sector of the minimum wage relevant? What is the situation for seasonal workers if they are (by definition) not working a full year? Is the expectation that the wage is sufficient for the year, or only the period which they are working for? How does this relate to plantations where workers have accommodation and food provided? Use of a ‘ratio’ here is superfluous as all it is are saying is that wages have to be at least equivalent to minimum wage.

Ratio is useful for benchmarking and continuous improvement. (PR)
ILO C131 is the basis for the minimum wage fixing. The definition of minimum wage is still often very controversial. (MG)
More practical guidance shall be provided for the cases where there is no national minimum wage, nor any recommended sector minimum wage. The ratio that includes  cost of living shall provide a reference for cost locally; When accommodation and food are provided to workers, deductions shall not an additional check shall be done for comparing the local cost of living to the deduction made for providing accommodation and food.

9

Add: equal treatment and equal remuneration for migrant workers and piece rate workers.
Add:  equal treatment and equal remuneration for men and women.

OK can be made more specific (MG)

12

How the “cost of living” is going to be measured? What standard of welfare is going to be applied? I can bet that this is a very polemic issue, because the concept of welfare of client countries is usually much higher of welfare in the producer countries. In other words, if it is expected that in Brazil or Africa the workers have as much benefits as they would have if they worked in Finland, any mill will be able to get the certificate.

Cost of living needs to be defined but shall include at least the basic components such as accommodation, food,  basic education cost for children in the country of the worker (at least average national cost shall used and if data exist, local cost if it differs widely from national average) and take into account family size. (MG)

14

What is the procedure in case there is no government defined minimum wage? Is it up to the producer to calculate it?

Some guidance shall be provided (MG)

15

Indicator 1: Comment – If the criteria states “living wage” there is a huge difference between minimum wage and living wage.
    Indicator 2: Comment – Need to be specific about the calculation for cost of living, does this include cost of food, number of people working in a family, family size, cost of education, discretionary spending, etc… All of this needs to be defined at a local scale because there are differences between specific countries.

Agree- See above comment on minimum wage and cost of living (MG)

16

In any case the wages prescribed must be sufficient to meet the basic needs of workers and their families
Incidents of violations may include ,
Overtime violations
Excessive, illegal, non-regulated deductions from pay which places a financial burden on the families
Hiring deposits as a condition of employment which are not regulated by law
Mandatory benefits not provided
Delayed/non-payments
Comply with the applicable law but, in any event, no more than 48 hours per week with at least one day off for every seven day period; voluntary overtime paid at a premium rate and not to exceed 12 hours per week on a regular basis; overtime may be mandatory if part of a collective bargaining agreement (required as per SA8000)
Verification:
Time sheets of all workers to be maintained
Adequately protected work clothes to handle hazardous materials (pesticides etc, chemicals for processing )

The proposed indicator 2.4.2 on cost of living targets a wage that meets the basic needs of workers.  
While 2.5 can address some of these issues when checking the form of payment.
The initial proposed indicator on working hours was not retained by the BSI Board in the selection for minimum criteria, but in progress.
Protective clothing (see criteria 2.3.2)

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2.4.1. This indicator should be excluded. It is not related to the company. Neither the cost of living nor the minimum local wages are defined by the company. Also, this issue is already covered by the definition of minimum wage by the ILO C131. The government needs to consider those issues when defining the minimum wage.
DG: I think we should disagree here.  Keep it in. ILO C131 is only mentioned in the document in this one place, in the notes column for this entry.  Furthermore, a signatory to the ILO can reject this convention, per Article 9 section 1 of it, which states:
“A Member which has ratified this Convention may denounce it after the expiration of ten years from the date on which the Convention first comes into force, by an act communicated to the Director-General of the International Labour Office for registration. Such denunciation shall not take effect until one year after the date on which it is registered.”
So it is not an absolute given that every signatory country actually accepts this convention.
More to the point, it cannot be assumed that just because the convention exists, that it is being followed by every player.  This is such a basic component of far play that it should stay.  Only companies who do not follow it should really have a problem, even if there is some “redundancy” with the law.

See above comment. BSI aims to promote sustainable production of sugarcane and this cannot be achieved if workers cannot earn at least a minimum salary but more important a wage that meets their basic cost of living. Countries might have a political stand around the type of conventions that they sign, but as responsible company, they shall adhere to a minimum wage level for their workers.

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1

An auditor needs to be satisfied that the contract meets a human rights standard.

Guidance shall be provided for helping the auditor in its assessment.(MG)

3

Need to set a minimum frequency of payment to employees.

Agree it would be good. The frequency of payment might however differ if workers are daily workers subcontracted and permanent workers. (MG)

4

Can the notes provide guidance on elements of such a contract e.g. hours, overtime, notice, holidays, wages?

Guidance shall be provided (MG)

6

Notes introduce 2 important new issues. ‘payment in form convenient to workers’ and ‘being aware of their rights’. Both of these should be in the criteria and indicators. They will be lost (and not audited) in the notes.
‘what is an equitable contract’? Suggest equity is covered in ‘non-discrimination’.
Clear information to workers related to payment (different situations in the harvesting, offices, industry, etc.

Need to define what is included in the contract. (PR)

I agree that these issues are important. Can be set as specific stand alone criteria, then adding to the number of criteria. (MG)
Agree with that equity could be covered in non discrimination (MG)

14

What’s the process for ‘non-waged agricultural workers’ as per Appendix 1 definition?

This is a tricky as the “non wage” takes the form of “barter”. Any suggestion from common practice welcomed.  (MG)

15

Should be provided at beginning of job. Should be more than just a contract, should be taken through what their rights are verbally, especially for illiterate people.

Agree it shall be specified (MG)

16

All information related to their nature of employment are made available in the local language and all parties involved (to include all workers, sharecroppers, contractors, subcontractors) are made aware of their rights and duties
To ensure disciplined working relations: No corporal punishment, mental or physical coercion or verbal abuse

OK to be provided in guidance.

18

No criterion is set on working hours (RTFO 6.12 is a recommendation only)

BSI board decided to take this not as a minimum which is the standard under consultation but then as a progress. (MG)

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2

Existence of a social plan for the workers whose job is affected by efficiency and modernization of production and processing
It is a responsibility of the State and not the company’s.  It could be a plus (eventually for a gold standard), but not an indicator.

Companies are deciding to implement efficiency and modernization of production and processing for business motives.  The decision might be linked to legal requirements, but it remains the responsibility of the company to have a social plan that shows what can be done to assist the workers within the company (training and other measures) and through governmental programs.  Further discussion is needed to clarify this indicator. (MG)

4

Presumably a social plan would only need to prepared when an efficiency programme was being developed - not in anticipation of one

It could be required for the decision of the efficiency programme.(MG)

6

2.6 Really hard to achieve this in practice. It should be linked to 5.8 and involve Government, NGOs, UNIONs etc.

Agree that there shall be a link with 5.8 (MG)

15

Should be legal safeguards for when people become redundant for severance. An employment contract is not necessarily a safeguard for life. This indicator should not be included because it could lead to the use of labour contractors rather than direct hiring. This should defer to the local law as a minimum, and up to the individual discretion, existing labour agreements, or local customary practice that may exceed this.  Could become an excuse to not address serious environmental problems (burning) by slowing adoption of innovations

Labour contractors should be an option, providing they conform to Criterion 2.2. (PR)
Employment contract should include severance clauses (PR)
The aim is not to prevent the adoption of innovation or modernization, but to ensure it is done respecting a fair and equitable treatment of workers. I agree that to avoid such criteria, the use of labour contractors could be increased. Labour contractors shall have similar rights as per 2.8. Additional safeguards shall be introduced and more discussion is needed on this indicator (MG).

2

3.1.1 –The note in the indicator does not define the raw materials considered. Given the current standard value, it is assumed that only sugar cane is considered, especially as the mass of other raw materials is negligible when compared to sugarcane´s mass. Therefore, even though we understand that efficient use of other raw materials is an important sustainability index, for practical reasons, we should consider the quality of the raw material. As a conclusion we suggest that the indicator should consider the amount of sucrose per hectare.
Standard suggestion: >7 tons of POL (sucrose) / hectare, calculated as tons of sugarcane per hectare times its sucrose content (POL).
3.1.2 –The standards listed in annex 1 are acceptable. However, there might be different methodologies for its calculation. As a consequence, the world “effectively” should be included in the verifier.
Verifier suggestion:  tons of cane effectively harvested / hectares effectively harvested / year.
3.1.3 – It is very hard to get a proper measurement of this indicator in a large commercial scale. A potential solution would be to measure only the biomass that is brought to the plant. However, as the majority of the plants currently leave the straws in the field, in practical terms this indicator would not be any different than the previous one (3.1.2). As a consequence, we suggest that it should be removed.
Standard suggestion: removing it.
3.1.4 – We agree with the purpose of this indicator. However, its content is very similar indicator´s 2.3.1. As the one proposed at indicator 2.3.1 is internationally recognized and utilized, we suggest that indicator 3.1.4 should be excluded.
Standard suggestion: removing it.
3.1.5 –This indicator should consider the recovery of milling/grinding as the percentage of time in which the effective milling received cane (discounting all the stops, including due to rain), divided by the total time (in cases of several mills/diffusers, it should be weighted in accordance with each mill/diffuser’s capacity). This is the calculation that is currently done by the Brazilian mills to measure its extraction efficiency.
Standard suggestion: 80% recovery of the extraction (mills/grinding and diffuser)
3.1.6 –This criterion should not apply for mills that produce both sugar and ethanol. In those cases, the mill’s efficiency is already treated in indicator 3.1.7.
Standard suggestion: it should not be applied for mills producing both sugar and ethanol.
3.1.7 – The industrial efficiency in Brazil is monitored by CTC in the center-south region’s mills (high technological levels). However, in other regions, for example the northeast, the industrial efficiency is much lower. As a consequence, the standard should be reduced to the Centre-south minimum : 70%

3.1.1 The major raw material is cane. We could have simplified the indicator by using the cane/sugar ratio and neglecting other raw materials, particularly as the mass of other raw materials is small by comparison. However one of the major issues in sustainability is the efficient use of raw materials and so all raw materials are included. In terms of making a significant impact on this indicator, in the example you have given, only lime and caustic soda need to be included in addition to cane in this metric. (PR)
The quality of the raw material is accounted for in criterion 5.3, and water usage in 5.2 (PR)
3.1.2 A clearer definition in the notes should suffice. Agree – or at least we would need a clear definition of tons cane harvested and of ha harvested to allow inclusion of seed cane from partially cut fields – but I think generally the original wording does cover this (PT)

3.1.3 Agree – remove (PT)
3.1.3 In the case of a mill exporting power (and in the future for 2nd generation alcohol), the yield of biomass is more important than the yield of cane and would have different standards. Perhaps it should be excluded, but have 2 different standard values for power export and no power export. (PR)

3.1.4 is different in concept, and fits into the category of efficiency, rather than safety. (PR)

3.1.5. This item needs a more detailed definition. In most countries, the Overall Time Efficiency is the percentage of the season that the mill is processing cane i.e. accepting cane into the cane preparation plant. That is what is implied in this indicator. In the case of a mill having two or more extraction lines with one down for mechanical or other problems, this is taken into account on a pro rata basis. (PR)

Agree that 3.1.6 should apply to mills that do not make ethanol or use only final molasses. I suggest that biomass yield and sugarcane yield be combined, with two different verifiers for case of no power generation and for power export 
Either 3.1.6 or 3.1.7 should apply, depending on whether sugar only is made (3.1.6) or some ethanol is produced (3.1.7)  (PR)
3.1.7 Should apply to mills using crystallizable sugar for ethanol production. (PR)
Standard for 3.1.7 should be 70 as suggested. (PR)

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3

I do not find the Sugarcane Yield and Biomass Yield in Appendix 1 of this document.  Are they really referring to the “BSI GHG Calculation” document?  The metrics given in that document are interesting, but there should also be the option for an operator to develop similar but perhaps even more relevant or advanced criteria/metrics.  This topic is too new to close it off yet; of course the standard can and likely will be revised in the future, but the due process involved with that could unnecessarily slow down advancement in people’s understanding and practices.

They are there (PT)
Appendix 1 does have definitions (PR)
New metrics can be devised in future if necessary or useful. (PR)

6

3.1 Is there some scope for regional figures for raw material, sugarcane and biomass yield? These vary considerably both within and between countries.
This criterion has a ‘working hours lost as a percentage of total hours worked’ and is set at ‘<3 %’ (processing and milling). How does this fit with the indicator in 2.3 ‘lost time accident frequency’, set at ‘<10 [accidents?] per million hours worked’.
Very complex situation. Could drive management to incentive or require workers to work more hours. May also create perverse incentive to try to get people to keep working even if injured or ill.
The Principle suggests continual improvement; however this is not reflected in the ‘standard’ (threshold).

For cane yield and biomass regional differences I think will have to be considered. Pilots may illustrate this. Alternatively measure actual and use as baseline for future annual audits. (PT)
It is hoped to have universal figures. Pilot test will indicate whether regional variations are required. (PR)
3.1.4 is different in concept, and fits into the category of efficiency, rather than safety. (PR)
The criterion “working hours lost as a percentage of total hours worked” is broader than the one as accident as it includes absenteeism, lock-outs. If kept it shall indeed be cross-referenced to the one on accident ratio to avoid the unintended consequence to get people working even if ill. (MG)

10

This section can only be checked by someone with specialist knowledge of the sugar industry, UNLESS training programmes will be provided for non-industry reviewers.

Specialist knowledge is available (PR)

14

Were the standards listed based on higher efficiency producers such as Brazil? How to accommodate less efficient producers in poorer countries?

Suggest consider baseline system. (PT)
It is not intended that the standards are elitist, but adequate practically achievable operational values. Values still to be set by pilot studies. (PR)

15

Indicator 1: Needs clarification as to whether this is sugarcane, sugar, ethanol, molasses, etc… being the product. Define “raw materials.” Is this active ingredient?  What does this try to accomplish? If this is ag inputs, this incentivizes the grower to seek the most concentrated inputs possible thereby increasing environmental and safety risks. Is water a raw material? This indicator is seemingly not necessary and will be hard to quantify.
Additionally, Indicator 5.2.1 Net water consumed per unit mass of product should be in this indicator or principle set, as water is an input.
Indicator 2: This treats water as the only limiting factor for yield. Need to somehow account for ratio of N to yield, soil type, etc… Should be within the top 25th percentile of regional cane yields. That would be more relative to the environmental and resource factors with fluctuations in seasonal rain, etc… Should also clarify what a hectare is – e.g. intercropping in some regions prevents farmer from growing dense cane. Must ensure that this encourages the industry to continue to improve. Clarify reference to the appendix, too.
Indicator 3: See comment above.
Indicator 4: Why isn’t this in the social part with other injury related indicators? Seems redundant.  Is this metric driving people to be encouraged back to work even if they are still injured? Recommend eliminating it. You want low hours of injury, but this could penalize workers.
    Indicator 5: Other question around efficiency is what is the relationship between mill efficiency, processing amount, and rated capacity?
    Indicator 6: Need to have transparent and common approach on potential sugar with regards to variety and seasonal impacts.
    Indicator 7:  Comment – good, see above.

1. This indicator applies only to processing and not agriculture. Thus the major raw material is cane. We could have simplified the indicator by using the cane/sugar ratio and neglecting other raw materials, particularly as the mass of other raw materials is small by comparison. In terms of making a significant impact on this indicator, in the example you have given, only lime and caustic soda need to be included in addition to cane in this metric. Water usage is excluded, because it is included in 5.2 (PR)

4. The criterion “working hours lost as a percentage of total hours worked” is broader than the one as accident as it includes absenteeism, lock-outs. If kept it shall indeed be cross-referenced to the one on accident ratio to avoid the unintended consequence to get people working even if ill. (MG)

5 The indicators should all be viewed as a whole (PR)

6 Adequate measure of recoverable sugar should drive variety development and usage patterns. This indicator deals only with processing recovery. (PR)

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3.1.1 It needs a clearer definition of the raw material considered in the industrial process. In weight the other inputs are not relevant. Should we consider only sugar cane as the single input (the only one relevant in terms of weight) (if not, the inputs need to be listed)?
DG: Good point.  While cane will be the large majority, what about the lime, phosphoric acid, etc., that might be used.  Even if a small percentage overall, we are talking about tons of material, which does have an impact and should also be considered.  Aside from the two inputs I mention here, what else should be considered?  Flocculants?  Others?
3.1.5. Do you agree that only the milling time should be considered (to discount, for example, the time when the milling is not working due to rain)?
DG: Discounting the weather seems fair, as long as there is a fair way to do it and it is not abused to fudge the numbers.  There would need to be a clear set of criteria for what to exclude, under what conditions, how it gets reported/calculated, etc.
3.1.6 Do we have an agreement that this indicator does not apply for mills that produce both, sugar and ethanol (CTC suggestion)? Only the 3.1.7 will apply in that case.
DG: I do not see what t should be limited to mills that produce both.  What if they do not produce ethanol?  Their overall efficiency calculation may be different, but it is a valid number nonetheless

.

3.1.1 Comment addressed above. (PR)

3.1.5 needs clear definition (PR)

3.1.6 must be retained for mills that do not make ethanol. (PR)

Key

1

It is very important that we monitor the effects of sugar cane on climate change.
Although along with the negatives we should also include the amount of carbon captured and eco –systems services provided by sugar cane.
Graham Kingston at our second meeting in London quote sugar cane as being  2.6 to 1 positive  for the capture of carbon

It seems we need to include an indicator on carbon capture specifically. (PT)

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2

As this is a highly complex issue it needs further debate. However, we would like to make one general suggestion about the criterion and a few comments on the proposed methodology for GHG calculations.
General suggestion: Criterion 3.2 should have two indicators, one for sugar and one for ethanol.
Comments on the proposed methodology (in appendix 3):
•    Direct and indirect effects:
o    SUGGESTIONS – (A) The emissions associated with the production of the industrial machinery are being abandoned in many lifecycle analyses, but we have no problems with maintaining it in the methodology. (B) We agree that indirect effects are extremely hard to predict and almost impossible to calculate the burden of a specific mill, as a consequence it should not be included in the analysis. (C) We strongly recommend that the BSI adopt the proposed cut of date (January 2008) for two main reasons: (i) the EU directive adopts the same date and (ii) ue to data availability. (D) We also agree with the consideration of carbon credits for biofuel production in degraded lands.
o    QUESTIONS – (A) Is direct effects going to considerer only “non-agricultural” areas or the potential conversion of “agricultural” areas as well? (B) Are pastures considered “non agricultural” areas? We recommend that they should (being potentially classified as degraded, when such characteristic is identified).
•    Handling of co-products:
o    SUGGESTIONS – (A) The co-products considered should be: sugar, ethanol, bioelectricity (eventually, excess bagasse). (B) We agree that the “substitution” method is preferred when possible. However, we strongly recommend that the marginal energy generation system should be used for displacement credits associated with bioelectricity exports to the grid. In countries where the average generation mix is very different from the marginal generation system (as the case of Brazil, where the previous is much less carbon intensive than the later), the claimed “conservative” estimates could be biased. It is the methodology used in bioenergy CDM projects and it would be a more realistic estimate (the marginal emissions are the ones that are actually substituted). (C) In cases where the “allocation” method is needed, the energy content should be used. The use of the economic value (as it is currently proposed) could generate important distortions when comparing the calculations for different countries.

Agree that Criterion 3.2 should have two indicators, one for sugar and one for ethanol. (PR)

S (A) It is likely that the BSI will adopt the proposed cut of date of January 2008. (PR)

Q (A) Direct land effects usually seem to be conversion of non-agricultural land only (PR)
Q (B) Pastures are non-agricultural in this regard. (PR)

(B) The use of average vs. marginal energy replacement is still being debated. We would like to adopt whatever the consensus of opinion is, in particular harmonizing with the EU directive. BS PAS 2050 dictates average generation mix. (PR)

(C) Agree to use energy content where sugar and ethanol are products. Economic allocation seems more appropriate for sugar and molasses (no ethanol production). (PR)

6

Criterion sounds ambitious ‘to monitor climate change impacts’. Suggests a monitoring of the global temp rise. Better to limit it to what is being asked – calculation of tons of CO2.
This needs to be elaborated significantly if it is to be included. In terms of the calculation, is this referring to mass of ethanol/sugar/molasses produced? Inconsistent terminology = ‘environmental burden’ ≠ ‘global warming burden’. 
Confused C&I; the criterion is simply to monitor, whereas surely it should be to minimise climate change impacts based on the indicator and ‘standard’

Could change criterion to “Monitor global warming emissions with a view to minimizing climate change impacts” (PR)

10

The total figure should be broken into its component parts so the areas of opportunity for reduction can be identified.

This is an automatic consequence of the calculation routine. (PR)

14

Are there plans to come up with baselines to accommodate producers that can’t pay for their own?

The use of default values in these cases for some of the inputs can reduce the cost/effort. (PR)

15

Does this include previous land use? Must create a formula to account for the different inputs, practices (tillage, burning/no burn, etc…), and their subsequent impact on carbon sequestration and emissions. Must create an agreement with a set global standard. Should defer to IPCC values, as well. Needs clarity and accompanying tool for farmers and mills to create the calculation.

Includes direct land use change (see Appendix 3). Attempting to harmonize calculation procedure with biofuels standards. IPCC default values are used, even though they sometimes lead to worst case scenarios. Spreadsheet for calculation has been developed. (PR)
Agree – will attempt to add more detail of farming practice effects (PT)

16

It would be appropriate to discuss climate change and impacts in the Principle 5. Hence, suggest shifting criteria 3.2 in the Draft to this section.

17

3.2 Would you agree with two indicators, one for sugar and one for ethanol?
DG: I think it is simpler and more to the point to map overall efficiency.  That is the goal.  Dividing it seems to me to perhaps only confuse the issue.  Or, both ways – itemized and overall – could be reported, as long as that was clear, and then people could do what they want with the data.  In all cases, at least the overall efficiency should be calculated

Separate indicators for sugar and for ethanol need to be introduced (PR)

18

BSI criterion 3.2 requires the reporting of global warming unit per unit mass product, which should always be lower than 0.4 tCO2/t sugar. In principle, the RTFO distinguishes between the reporting on environmental and social sustainability criteria (the RTFO Meta Standard) and separately asks for the reporting on carbon savings of biofuels. As various methodologies exist for the calculation of carbon savings, it is recommended to BSI to provide insight into the calculation and to leave the methodology open. In other words, producers could provide information on their business practices and/or key data points (e.g. tones fertilizer input, CHP use etc) which could then be inputted into any methodology - this might actually be more useful than the final GHG number, as it provides a more flexible approach.

The methodology must be prescribed and standardized, because different methodologies lead to different answers. The calculation procedure will be described in detail. It is hoped to establish a procedure which finds wide acceptance, particularly with bioethanol methods used by importers(PR)

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1

1. I am not sure how this is measured, if it is from the sugar residue on the cane after harvest this can be eliminated by spaying the trash with minute amounts of N.
2. This is good.
3 I think we should add into this leaf analysis tests as well as soil testing, many growers find then a better indicator , for use in a nutrient reduction program
4 The only cane growing area I have come across that has and measures this data is the Louisiana USA sugar industry
5 All operators should be trained before spraying chemicals.

Additional, that land managers only do practices that increase soil bio-diversity /do not reduce soil carbon

1. Measured in effluents/run off (PR)
Obviously we need to provide better explanation. Guidance document. (PT)
Note on 4.1.2 should be re-worded  (PR)
3. Agree this would be good to add leaf analysis – or perhaps have either leaf or soil. New wording Indicator=-Soil or plant nutrient status. Standard =% fields with fertilizer applied according to soil or leaf tests (PT)
4. Indicator needs better explanation – Guidance document (PT)
5. Nice to have – not sure whether essential and would add another indicator. (PT)

Difficult to achieve as many critical practices may cause soil carbon reduction – (PT) 

2

4.1.1 – Aquatic oxygen demand per unit mass product
The standard should clearly state that only direct effluent discharges into water bodies are considered. Also, we suggest that the verifier should be g.BOD/kg of product.
4.1.2 – High Conservation Value areas (interpreted nationally as described in App.1) at risk
During previous discussions the inclusion of High Conservation Value (HCV) areas in the standard was accepted to permit a minimum consensus, allowing the standard´s publication for the public consultation. However, we would like to point out again our concerns with this concept.  There is no internationally and broadly accepted definition and methodology to identify those areas. High Conversation Value definition is not recognized in any international convention. We are against its adoption, especially when it is extended to any kind of area, because identification of HCVs based on its toolkit is very subjective. We support the idea of protecting important natural areas but it is very hard to commit to something that is not completely transparent and subject to different interpretations. We suggest that this indicator should be re-discussed, trying to agree on a more acceptable indicator for this purpose.
4.1.3 – Soil nutrient status
A definition of the acceptable methodology and periodicity of the quoted “soil tests” are needed. Also, it should be clearly stated that only “organo-mineral” fertilizers are considered.
4.1.4 – Eutrophication per unit mass product
The measurement of the “risk” (quoted in this criterion´s note) is a very subjective concept which is, in practical terms, impossible to measure. Such “risk” refers, potentially, to diffuse pollution, being impossible to identify its origin and, therefore, it is impossible to responsible a specific producer for it. A practical way to deal with such problem would be to establish a safe maximum limit for the equivalent phosphate applied by hectare. That would be the only feasible way to address this issue.
Standard suggestion: <150 kg of equivalent phosphate applied / hectare.
4.1.5 – Ecotoxicity to aquatic life per unit mass product
The “eco-toxicity” concept needs clear definition if it is to be kept in the standard. With this lack of definition is not possible to address this criterion’s feasibility. Based on our understanding about this criterion, we suggest the following standard: herbicide and pesticide use (in active ingredient) per ton of cane.
Standard suggestion: <45g (in active ingredient) per ton of cane.

4.1.1 IChemE proposes the stoichiometric oxygen demand be calculated from an analysis of effluents. The use of BOD or COD (a quicker and easier analysis) could be used instead. (PR)
This was not explained well previously – Guidance doc needs to be produced and circulated again to these respondents for comment. (PT)
4.1.2 If an independent specialist body were contracted to conduct the biodiversity assessment in each country this could provide consistency (who would pay for this I don’t know). Agree the concept should be re-visited. I agree that HCV is not an internationally agreed concept and it is more important to have a clear statement of requirements rather than adherence to a concept which is not consistently defined (PT)

4.1.3 Guidance document will specify. (PT)

4.1.4 This sounds a good way of dealing with the issue agriculturally. Analysis of N, P and COD in effluents from the factory can be used to compute the eutrophication burden. (PR)
Needed to be explained better – will be in Guidance document. It in fact does exactly what they suggest and goes even further by allocating a potency factor to the mass of fertilizer concerned – mass x potency gives a very explicitly measurable value for risk. However this concept would be easier to apply if potency factors cannot be derived.(PT)

4.1.5 Ecotoxicity is calculated from analysis, looking particularly at heavy metals and certain specified organics. It may be easier to adopt the suggestion of mass of (herbicide+insecticide) applied per hectare. A check on heavy metal discharge from mill effluents may still be necessary. (PR)
I owe an explanation as above – same principle applies. But The suggested alternative is useful if potency factors cannot be derived. (PT)

3

In general, sections 3 and 4 do not lay enough emphasis on soil building and soil stewardship as an effective means of sequestering carbon and reducing the need for external fertility inputs.  Ecotoxicity should not be limited to affects on aquatic systems; terrestrial ones are equally important.   I find these to be key aspects lacking in the draft.  Without some better treatment of this topic, the Standard will not go very far toward improving core parts of the environmental aspect of the objective.  It might be “better” sugar, but not that much better.  Cutting out really egregious practices is indeed good, but the overall objective should be to turn the net destructive practices around and make them head in the right direction.
            Soil nutrient status is not well developed in this section.  Added fertilizer may be necessary, but soil organic matter would be a better metric of real progress.

Ecotoxicity could be calculated from quantities and analyses of chemicals used, assuming no degradation after application. (PR)
Accept soil building emphasis and terrestrial ecotoxicity comments as well as soil nutrient status. (It would have been  easy to list and audit practices which would address a number of these identified shortcomings -– not so easy to provide relevant metrics)  Whole section requires re- evaluation to ensure inclusion of these aspects and better explanation. (PT)

5

This section is extremely thin and requires further development. however it is recognised that this is a very difficult area of conservation science. however additional resources could be mobilised to help with knowledge generation to inform decisions in this regard.
no mention of control of alien invasive species, the importance of establishing corridors, buffers and management of open 'natural' or unconverted areas.
no mention of soil erosion mitigation

Agree with all these comments – many of these issues had to be removed from first list but do need to be reconsidered. (PT)

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P4 The Principle does not reference maintaining or protecting biodiversity (which may not always require active management) and ecosystems (rather than only the services they provide).
What about conversion? Cut off dates? Rare, threatened or endangered species?
Soil? Water? Air? Pesticides? Integrated pest management? Waste disposal? Burning?
No actual mention of biodiversity or ecosystem services in indicators.
HCV concept includes assessment, management and monitoring, but is only included here in relation to assessment. 
Also not appropriate to have a ‘yes/no’ verifier. ‘Standard’ column implies that the goal is to have no HCVs, but this is not in keeping with the HCV concept, in which the important element is the management of the HCV area in order to maintain the HCV.
Nothing about managing and conserving biodiversity on the farm or around it, beyond ‘not having’ HCVAs.

Cut-off date to be specified. (PR)
Again all very valid comments – one slight problem is the structure of our P&C – should water and soil and air fall under continuous improvement P5 or under manage biodiversity P4? The result is a disjointed approach to environmental aspects. Again a number of indicators removed from first list.  Will all be addressed in a re-consideration of these items.(PT)

Yes/No relates to whether the HCV is at risk IF IT EXISTS, if it does not exist on the farm then there is still no HCV at risk. (PT)

10

Like above, no "process" considerations, to show where areas of opportunity for improvement can be identified. LeafTc is experienced in this area.

11

To me it is impossible to cultivate sugarcane in a sustainable way. Sugarcane needs a lot of water. In Rainfall regions it conflicts with Rainforests and in dryer regions it needs irrigation. Irrigation can only be done close to water resources which should be reserved for food production.

Most cane is grown under rain-fed conditions without conflicting with rain forests. (PR)

14

HCV - How to accommodate the cost in the case of smaller producers where such studies have not been carried out at national level?
Soil nutrient status - where did the 80% standard come from? Wouldn't it be better to have it based on soil quality instead?

As it stands this must be carried out at national level. However issue needs to be considered.
80% is reasonable figure to achieve standard. Soil quality would vary too widely to set any specific level. (PT)

15

Nothing covering alien invasive plant control. Suggest that an indicator include measurable reduction in invasive ground cover in region.
    Indicator 1: Should call this Biological Oxygen Demand. This is a factor at the mill and at some points on the farm. This needs clarity as to how they are regionally appropriate. Is this trying to set a limit on discharge into the environment? Needs to comply with local legislation or internationally recognized data for freshwater and marine biodiversity requirements. Can have high volume discharge with low BOD, and low volume discharge with high BOD, with the same impact. The dilution rate is the factor that impacts it BOD. This is a complicated metric, must find a way to practically do it, or eliminate it from the lab unless there is extensive support to undertake the testing. Have to determine if this is a regional problem before mandating the tests and monitoring.
Indicator 2: Should integrate with 5.7.2. Not only should the assessments be conducted, but the habitat should be actively conserved and linked to other existing fragments in the agricultural landscape.
Vegetative buffer strips around water (and other sensitive ecosystem types e.g. wetlands, forests, grasslands) are often mandated in the HCV analyses. They should be mandated within the standard and maintained at a width and quality necessary to protect water bodies.
Need to be clear that all 6 HCV categories are included in the standard. Relevant and interested parties should participate in creating the HCV maps and classifications.
Indicator 3: Why 80%? This should be 100%? What will be the sampling protocol? What will be the efficiency rating of N application? Needs to set a limit of nutrient use efficiency to prohibit waste that harms local environment. N application must related to N uptake and export.
    Indicator 4: This should not be limited to phosphate, but to N, as well. We need to measure downstream risk and occurrence relative to the impact of the sugarcane planting region and farm. Should be related to output use efficiency, as well. There needs to be a leading indicator instead of an after the fact indicator. We want to prevent eutrophication. Should only be used in places where eutrophication is an issue and understand why.
    Indicator 5: Needs a standard, first

As before – Guidance document required and previous notes explanation was not sufficient. All these issues are relevant but some would be answered by explanation of indicators.  All need to be considered. (PT)
1 Most legislation only accounts for concentration of BOD, not mass of BOD. (PR)
Verifier for 4.1.1 should be kg/t and the standard should be 1.0

2 Standard 5.7.2 refers only to new projects (PR)

Indicator 4. Units are in P equivalent so all chemicals are included but converted to P equivalent (PT)
Calculation of eutrophication takes N into account as well, but the computed number is expressed in terms of phosphate equivalent. (PR)

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4.1.1 What are the effluents considered? They should be clearly stated. Could you explain exactly how is calculated?
DG: All effluents should be considered.  BOD is one way to measure, but assessing specific nutrient concentration and load might also be important.
4.1.3 What is the methodology for soil analysis and what is the periodicity of the analysis?
DG: Since this is criterion one of the weakest parts of the whole standard in my opinion, anything that can strengthen it will be welcome.  Analysis should be annual, at a consistent time of the production cycle, taking into account tendency for nutrients to leach due to rain, etc.  The objective is to get a real idea of soil nutrient deposition and content in a way that shows efficient use of fertilizers.  Criteria for sampling and analysis could be spelled out, but samples should be representative, lab protocols from standardized/existing/accredited methodologies, and results reproducible.
4.1.4 How can we objectively measure the risk? How do you assess the origin of the contamination?
DG: Good questions.  The notes explain that risk is not being measured, but phosphate deposition from the mill is (at least that’s what I think it says).  Origin could be from the mill or from fertilizers, and as such, the processing area should probably also be assessed even though the draft just says this point pertains to agriculture.
4.1.5 What is the definition of ecotoxicity? What are the products considered and how is it calculated? Could you clarify what does the verifier (t/t) measures? How can we measure the risk?
DG: Most pesticides have basic data about their LD50 levels and similar toxicity data, which could serve as a baseline.  But one would need to probably actually sample water supplies at key times to know what the levels really are.  Doing biodiversity assessments of aquatic species over time could also be a good indicator, assuming a truly thorough and accurate study was possible at the outset (may not be that good of an assumption).

Again – a better explanation of the indicators should have been supplied. All these questions need to be answered and a review completed of this section as indicated previously (PT)

Verifiers for 4.1.4 and 4.1,5 should be t/t cane, not tt/cane (PR)

4.1.5 Ecotoxicity to aquatic life. A range of metals and compounds are included in analysis and computation. The verifier is tonnes formaldehyde equivalent per tonne cane for organics, and tonnes copper equivalent per tonne cane for metals. (PR)

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18

Although criteria are set on processes that could endanger biodiversity the RTFO criterion 2.3 is not fully complied with as no criteria have been set on mitigating and monitoring the impact on biodiversity and endangered species.

Need to address. (PT)

18

Extend the list of best practices for soil conservation with criteria on erosion, salinisation and soil structure. (here or 5.2)

Need to address. New indicators to consider soil erosion, salinisation and soil structure. (PT)

2

4.2 – Documented consultation plan
The definition of the plan’s structure needs to be the mill’s responsibility.

Guidance to be guided on consultation process. Plan shall include all risks areas, details to be adapted to specific local mill situation.

6

Only requesting mitigation measures. Nothing about preventing negative impacts. This is very weak. It appears that just a plan is enough.
Reference to stakeholder consultation and mitigation measures should also link to an ESIA.

Agree that consultation shall be on preventive measure too and risk assessment of ESIA could provide base. All indicator needs to be reviewed(MG)

9

Specify stakeholders, and make sure to include women

Should identify stakeholders in Appendix 1 definitions (PR)
OK  (MG)

10

Use of "etc." is dangerous!

Fair enough – take out. (PT)
Agreed (PR)
Agreed (MG)

15

Should be able to demonstrate that the documented plan was implemented. Must ensure that there is an open and transparent process to engage relevant and interested parties. There should be a documented process that has been implemented.

All indicator to be reviewed (MG)

No criterion is set on burning for land clearance or waste disposal. BSI reason that this is included in the calculation of GHG emissions, but the actual problem of burning is air quality (particulates) and not GHG emissions. Furthermore, residue burning should not show up in the GHG emissions as these are part of a short carbon cycle and thereby do not   form a net emission.

Needs to be addressed. (PT)
The control of cane burning and particulates fall-out should be a part of the standard. (PR)
Residue burning does have a substantial effect on GHG emissions, through the generation of N2O and CH4 in burning. (PR)

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18

Burning before harvesting is not mentioned currently in the standard while this practice has negative impacts on local air pollution and soil carbon (although soil carbon itself is included in a criterion). Burning before harvesting is known to be a contentious issue for sugar cane as it also impacts employment. In addition, mechanical harvesting may not be feasible in some areas due to terrain conditions. Nonetheless, burning is a serious issue in the sugar cane industry and it would be a positive development if this issue was at least recognised and preferably addressed in some way in the BSI standard.

1

Soil acidification, there would be no one in the world who could comply with this a quick sum on this it would cost around AU$1.00 per ton to comply. A more realistic value could be every crop cycle or 5/10 years acidification does not happen quickly.
The 4.4 –8 .0 pH  may not be achievable, there are papers that have been written that show sugarcane can grow quite successfully with pH’s  as low as 3.0 pH  and some areas of Australia and I assume other parts of the world  where irrigation water is pH 9.0 (one of the better producing areas of Australia)

Organic carbon: An honours study showed that under sugar cane cultivation organic carbon levels will reduce at about one percent every 30 years.
Some growers have actually been able to turn this around and have shown increases in organic carbon levels from 4.5 to 6 % in 15 years through green cane harvesting (GCH) trash retention and minimum to zero tillage.
It is very important that trash retention on farms is not replaced with whole of crop harvesting system to benefit the mills for co-generation, at the detriment of the farms soil health, nutrient balance and soil biodiversity

We could use a baseline value system. I.e. measure existing and then compliance depends on not being worse on an annual basis - This would be necessary to show continuous improvement. Needs attention. (PT)

 Baseline value system would be appropriate here as well. Necessary for continuous improvement anyway. Would need to consider whether it is feasible to expect growers to prevent Organic carbon from decreasing over time. (PT)
Agree there is a direct loss to the farm of whole crop supply to the mill – at least part of the crop should be retained. This makes biomass yield not desirable as an indicator of productivity efficiency for growers. (PT)

2

5.2.1 –It does not make sense to consider rainfall in the calculation. For example, see comments previously sent to the group leaders:
In the case of Sao Paulo rain around 1500 mm, that means 150 m3/t cane or 150,000 kg/100kg.sugar, resulting in 1500 kg water / kg sugar or 15000 kg/68.kg.etanol = 220 kg / kg ethanol (just to illustrate the discrepancy in the use of rainwater in the crop in regions with plenty of rain, which would be penalized without reason).
In my opinion you should consider only the use of irrigation water (the Hydrical Resources´ pressure).
In the mill, the water uptake is around 2 m3/t cane, which returns to the environment by discharging into the river or by ground irrigation. How should we consider? In Brazil it is considered only the part that returns to the rivers and in the case of the soil, it is considered losses. So I suggest you move to the concept:
Water consumed = water captured (surface and/or underground) - effluent discharged into rivers.
Therefore, only the balance of captured water for irrigation and for industrial use should be considered. Rainfall and water re-use must not be included.
Standard suggestion: <100 kg/kg of cane (agriculture) and 45kg/kg of sugar or ethanol (industry).
5.2.2 – Soil organic carbon
Observe that up to 25% of clay in the soil, the equation of soil organic carbon presented is equivalent to the concentration of organic carbon obtained by the ratio shown in Table 3 (organic matter/1,724). From 25% in clay soil, however, observed that the equation gives us organic carbon of 3,116, above the value obtained by our ratio (1,740), which allows us to conclude that the linear formula presented is inappropriate and could jeopardize Brazilian soils with high clay content, as the Brazilian region of Ribeirão Preto. It seems that a parabolic correlation must be more appropriate
5.2.3 – Soil acidification
The methodology for the measurements needs to be specified in the text. Also, it is not feasible to demand annual measurements for all the planted areas (they are not necessary). In addition, there is a relevant shortage of specialized laboratories in Brazil for those analyses, many times the measurements must be booked months in advance, which makes annual readings for all the areas impracticable.
Suggestion of methodology: consideration of water pH, measurements should be done in during the sugarcane field reform, depth of the measurements should be within 0-0,25cm and 0.25-0.50 cm.  An average of 5 years should be considered to monitor changes.

I agree that rainfall should be kept out of the water usage calculation, for the reason you give. (PR)
Agree -Adjust indicator to take this into account. (PT)

Your interpretation of water usage calculation in the factory is correct. In a factory without ethanol and cane washing, a negative value is expected. Both these factors complicate the situation. In addition, the use to which vinasse is put (return to the fields, or to effluent after digestion, or with evaporation) will influence the number. (PR)

5.2.2 Use baseline system rather than trying to establish comparable values. (PT)

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5.2.3 Constructive comments – need to be taken into consideration. (PT)

5

metrics mostly impractical due to high variation between soil types. metrics need to be country specific and locally metrics for soil - applicable to soil type to be meaningful. a practice based approach may be more appropriate to account for the large geographic based variability in soils.
water quality metrics impractical: expensive, require specialist collection and analytical procedures, difficult to attribute to a causal agent in complex multi-use catchments, require long term flow data to be meaningful, require reliable flows, impractical for small growers, more appropriate at landscape scale than farm, don't account for episodic pollution occurrences’ (as opposed to biotic indices).

Accept  comments – need to consider carefully whether a change in approach is actually warranted. In the first instance rather default to baseline measurement system where possible. (PT)

6

Very difficult to measure net water consumed. Too expensive to do it.

Alternative method proposed by UNICA –to be considered. (PT)

10

Normally biotic indicators would be included in this section. LeafTc is experienced in this area.

12

I can't understand why rainfall is going to be included as "water consumed per unit mass of product". Is it fair that more humid areas are penalized by the certification system? Is the impact of using water from the river or underwater similar to producing in a rained system? I don't think so.

Alternative method proposed by UNICA –to be considered. (PT)
Agree rainfall should be omitted. (PR)

14

We suggest expand to take into consideration different types of soils.

Agreed – but possibly move to baseline system to avoid problem of variation. (PT)

15

Indicator 1: Need to restructure so that the indicator drives behaviours to efficiently use water. The current metric does not account for seasonality, rain fall patterns, rain fall frequency, soil type, irrigation source recharge from over-application of water. This should be an efficiency metric based on extracted to utilized by the plant and relative evapotranspiration to native vegetation. Need to account for the fact that water scarcity is not always an issue and therefore rainwater may not need to be measured. 
Water use via irrigation (need to think about the behaviours we want to motivate) should be based upon soil moisture characteristics and the crop requirements at the time. This should be a localized standard.
Also should show how the <100 kg of water per kg of product (is this product cane or sugar or ethanol or molasses or bagasse?) figure was arrived at.
This metric should be segregated between agricultural and processing, in order to better assess use at both levels of sugarcane production and processing.
Need to understand if the area is water scarce and the potential impacts on other, downstream users.
    Indicator 2:  Again, what behaviour are we trying to achieve through this? Need to make sure that this is applicable for a smallholder? Advise how to do this aside from just providing the calculation. Need to account for soil type, soil moisture, N, and temperature fluctuations. How often will this be measured during a year and how do we account for variability?
    Indicator 3: Fine. Need to consider eliminating this because it is unclear as to how this is an actual sustainability factor. It is clearly the optimal range for cane to grow in it and we do not want people to mismanage their crops and soil. We should focus on preventing degradation of pH over time. Some regions have soils below this pH, but they can still produce a crop through management practices (e.g. acid sulphate soils)

The product from agriculture is cane and the product from the mill sugar and/or ethanol. (PR)
Clearly a requirement for review of this indicator (PT). Obviously need expert input and advice on a suitable indicator here!! (PT) perhaps even different to the suggestion of UNICA.

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Change to baseline measurement system.  (PT)

Change to baseline measurement system. (PT)

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5.2.1 In the case of Sao Paulo rain around 1500 mm, that means 150 m3/t cane or 150,000 kg/100kg.sugar, resulting in 1500 kg water / kg sugar or 15000 kg/68.kg.etanol = 220 kg / kg ethanol (just to illustrate the discrepancy in the use of rainwater in the crop in regions with plenty of rain, which would be penalized without reason).In my opinion you should consider only the use of irrigation water (the Hydrical Resources´ pressure). In the mill, the water captation is around 2 m3/t cane, which returns to the environment by discharging into the river or by ground irrigation. How should we consider? In Brazil it is considered only the part that returns to the rivers and in the case of the soil, it is considered losses. So I suggest you move to the concept:
Water consumed = water captured (surface and/or underground) - effluent discharged into rivers.
In this case, the maximum would be the total consumption of 2 m3/t cane (equal to the volume captured), that is: 2000 kg/100.kg.sugar, equal to 20 kg / kg sugar or 30 kg / kg ethanol
Peter´s Response: In the case of agriculture, the product is sugarcane. I agree that rainfall should be kept out of the water usage calculation, for the reason you give. However I would like Peter Turner’s opinion. (DO YOU AGREE WITH CTC AND PETER?)
DG: Excluding rainfall from the calculation seems reasonable to me, but well water should also be considered along with irrigation water.  Also, if rainwater is captured and then used for irrigation, then should be included, since the capture could be robbing other areas of that water.

As indicated before water indicator needs review. (PT)

Review of all agricultural indicators required.  (PT)

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5.2.2 (CTC comments) Observe that up to 25% of clay in the soil, the equation of soil organic carbon presented is equivalent to the concentration of organic carbon obtained by the ratio shown in Table 3 (organic matter/1,724). From 25% in clay soil, however, observed that the equation gives us organic carbon of 3,116, above the value obtained by our ratio (1,740), which allows us to conclude that the linear formula presented how standard is inappropriate and could prejudice Brazilian soils with high clay content, as the Brazilian region of Ribeirão Preto. It seems that a parabolic correlation must be more appropriate.
Table 3 – Comparation between the equation´s soil organic carbon

DG: The main objective should be the increase of carbon in any given soil.  In that sense, as long as the metric any operator uses is valid and used consistently, they will have something to compare over time.

As indicated before default to baseline measurement system. (PT)

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Include criteria on preservation of above and below ground carbon stock. This should be accompanied with a reference date of 30 November 2005 (as currently stated in the RTFO) or January 2008 as will be required under the European Renewable Energy Directive (which will replace the RTFO reference date). One option for BSI is to include this criterion in their calculation of lifecycle GHG emissions (BSI criterion 3.2). However, a detailed GHG-methodology may not be the best solution for BSI to deal with carbon issues.

Reference date still to be decided. (PR)
Carbon stock where direct land use change is involved is accounted for in GHG calculation. (PR)

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5.3 – Theoretical recoverable sugar in cane
This issue is already treated in other indicators (especially if our suggestion for indicator 3.1.1 is accepted). Industrial efficiency is a broader concept that takes in account all the products, ethanol included.
If we understood well, the proposed formula takes in account: undetermined losses (2%) + extraction losses + recovery at the factory, which would yield an average of 86-89%. We do not understand the 10% standard.
Once this indicator deals with extraction x factory recovery, it is only applied in sugar production. In the Brazilian sector, CTC utilizes other formulas with other coefficients (more adapted to our reality).
Standard Suggestions: removing it (it does not reflects the quality of the sugarcane, but only the efficiency of an only-sugar factory).

This is a measure of cane quality, not yield/ha (as in 3.1.1). There are various measures for cane quality. The most important of these is the amount of sugar that can be recovered from it. The 86-89 % refers to the sugar in cane; the number proposed here is recoverable sugar % cane, i.e. 86-89 % of the sugar content of cane, typically 13 %.(PR)
The calculation and its derivation will be attached in Appendix 1. (PR)
Bear in mind that most factories in the world do not produce ethanol, and so this cane quality factor is very important. (PR)
It may be possible to generate an equivalent quality parameter for ethanol only manufacture – theoretical recoverable ethanol in cane. (PR)

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The ‘continuously improve’ part is inconsistent with the indicator and standard, which is a fixed threshold. Unclear over what period this would be calculated (single sample? Annual data?) Again, what if it is already maximised?

The standard set initially is quite low. (PR)
Calculated over a reporting period, typically one year. (PR)

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Calculation needs explanation of symbols. Otherwise this could significantly raise the bar, though we suggest 10.5-11% recovery. Should also put pressure on mills to eliminate waste flow.  How much is in the effluent water, how much is still on the bagasse? Should be broken down to promote efficiency at the growing/harvesting, transport, and mill end.

This is a measure of cane quality only. Recovery efficiencies are covered in section 3.1. (PR)
Suggest wording of indicator to be changed to “Theoretical recoverable sugar content of cane” (PR)

Key

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5.4.1 – Total net primary energy usage per kg product
The negative energy usage in the industry is only obtained when there is excess bioelectricity exported to the grid. Considering only the agriculture sector, it is impossible to achieve it. Also, there are not many sugar/ethanol plants in the world that export electricity outside the Brazilian Center South region.
Standard Suggestions: A positive value should be established.
5.4.2 – Energy used in cane transport per ton cane transported
It does not make sense to include the Brazilian figure in the note. It should be excluded. We also would like to ask what is the source for this number? A recent article by Macedo & Seabra (2008) in “Sugarcane Ethanol: contributions to climate change mitigation and the environment”, published by Wageningen University, estimated those values in Brazil at 37 MJ/t in 2006 and 45 MJ/t in 2020.

5.4.1 Agreed negative energy only achieved with power export. There are many other countries apart from Brazil where this is practised. It is not anticipated that negative energy usage will be achieved in agriculture on its own. (PR)
5.4.2 Note should be removed –it is not correct.
The numbers you quote are consistent with the preliminary standard value. (PR)

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Excludes producers not sophisticated to have co-gen. More of a goal than a standard

Agreed. A positive value will need to be used, probably about 300 MJ/t cane (PR)

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Indicator 1. Good, but should be considered at aggregate level between feedstock farms and mill. Needs further explanation. What needs to be measured and how? Not sure if this is practically implementable for a farmer, especially small growers
    Indicator 2. Should be adapted to focus on fossil fuel use per ton cane, not in MJ. Who is eliminated from this, or is the bar set so low that everyone will be included? How did they come up with this rule?
    Indicator 3. Should translate this to an amount of fossil fuel, something that the farmer does pay attention to, or provide calculation of MJs in different fuel types. Does this include homestead electricity? What are we trying to do with this metric? What is the definition of primary energy? Does this not overlap with 5.4.1? Could this be merged with 5.4.1?

1 The calculation of net energy usage is integral with the calculation of GHG emissions. It takes into account indirect as well as direct effects, and is explained in the write up on GHG emissions. (PR)
2 Value still has to be tested in pilot studies. I am not aware of any fuel other than fossil fuel used in cane transport. (PR)
3 Covers all types of energy, identified in calculation routine. Specific to growing sugarcane. (PR)

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5.4 (CTC comments) Negative consumption of primary energy (electricity and fuel purchased) for the manufacture of products is impossible, especially in the field. In industry, the parameter is more acceptable if it considers the sale of energy produced. Please send methodology.
Response: Negative energy usage is obtained with export of electric power in many cases. In cases of little or no export power, a positive value will be required. The calculation of net energy usage is integral with the calculation of GHG emissions. It takes into account indirect as well as direct effects, and is explained in the write up on GHG emissions, which I will send you. (COULD IT BE SENT TO US? The formula needs to be clear and separate from GHG emissions for easier analysis by the interested mills)
DG: I basically agree with the response above.  Calculating the final number I believe is still a work in progress and that the methodology will evolve over time.  Having a consistent way to do it is good as long as it can be updated as people learn more.  To that point, if an operator has a better way of calculating, they should be allowed to do that and show how it differs from the standardized way; this could help facilitate overall progress of knowledge.

Some default values are used in calculation. Better data than the default values should be used where available. (PR)

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Growers’ research and extension costs per unit value added as %
First, this indicator should apply for both, agriculture and the industry. Investments in industrial developments are as important as the ones in agriculture for continuous improvement (principle 5). Also, it must be clearly stated that contributions and partnership expenses with research institutions are included as “research and extension costs”. Finally, the unit value added is a complex calculation that potentially deals with commercially sensitive information. It would be better to establish the indicator research costs as a percentage of the earnings. As the value of gross earning is much higher than the value added, the percentage value should be reduced.
Indicator Suggestion: research and extension costs as a percentage of the gross earnings. Standard value (%) still needs to be determined.

Need to consider (PT)

5.6-5.9 are not about continuous improvement.   Also, when considering continuous improvement, it will be important to consider how to reward those already performing well, vs. rewarding those that have a long way to go and thus can show continuous improvement with less effort.
5.6  not clear. Research and extension costs as a % of what?  Notes say ‘can relate to industry or farm’ but only ‘agriculture’ column has a dot. No way to know based on indicator whether research is ‘effective and focussed’.

Fair comment - need to consider (PT)

Agree that best performers need to be rewarded. This relates to the value that can be attached to certificate and other system to recognize performance (MG).

Who should pay for it? If it is management practices, it can’t be regulated as more a goal then a standard.

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How do we define problems and problem solving for R&D? How do you define extension and measure its efficacy? Are field supervisors who are agronomists also extensionists? Metric assumes that more than 1% of total cost will solve problems. How was this developed? Based on what evidence? Suggest eliminating this indicator.
Would prefer field evidence of innovation (extension system in place?) rather than this metric with some percentage.

Guidance will be required. (PT)

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5.6. Just to clarify, contributions for research institutions are included. Right? Why does it apply only to agriculture and not the industry (it should be both)?
DG: I agree – wherever it s found to be a valuable contributor should count.

Correct. Also should apply to the industry (PT)

Expansion I see is the main problem facing our standards , and the mother hood statements above while they are good need to be  able to ensure that the environmental and social impacts not only are addressed but in fact at the end of the day that they are complied with.
I see this as our biggest challenge with the NGO’s

5.7.1 - Recognized EISA (Environmental and Social Impact Assessment)
Again, the cut-off date should be established at January 2008.
5.7.3 –HCV areas used as % of total land affected by a new project or an expansion
The same comments made for indicator 4.1.2 are applicable here (subjectivity and lack of clearness on the HCV definition). The adoption of another concept should be discussed for this indicator. Anyhow, a cut-off date will need to be established to monitor expansion. We strongly suggest that it should be January 2008 to be in compliance with the EU Directive.

Agree (PT)
Cut-off date still to be established (PR)
Agree cut-off date should be established (MG)

Implies need for an assessment, but no requirements about avoiding negative impacts or taking preventative measures, or addressing problems.  Also not explicit that ESIA and consultation must be carried out prior to expansion. The text should be clearer about the relationship between the areas required to maintain or enhance the High Conservation Values versus identification and management of the values themselves.
We strongly suggest that more work is done on the use of the HCV concept, and that clearer explanation is given in the standard about how it works. Central to the HCV concept is the idea that you first identify whether you have any High Conservation Values present – (this is not the same as an HCV AREA). You then decide what is the area needed to maintain or enhance this value. This area then becomes your HCV area). Therefore it may be the case that an operation could have a particular VALUE, and still be able to clear some land to manage for sugarcane – providing that the area needed to maintain the value is not affected.
As it stands at present it is unclear whether the identification of an HCV area within a potential expansion area would prevent expansion over the whole area, or only prevent conversion of the HCV area.
n.b. HCV concept not designed to allow identification of areas at national level – local interpretation always needed.

If a recognised ESIA has been conducted then I would have thought it goes without saying that the results are applied. Maybe I am wrong. Could adjust wording.(PT)

Agree that preventive measures need to be linked to ESIA (MG)

Agree HCV needs further explanation, clearer definition. (PT)

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Extremely unwieldy title from which it is difficult to extract a meaning!

Tend to agree. (PT)

This overlaps/duplicates to a degree with 4.2
    Indicator 1. Recognized ESIA. OK, as long as recommendations are followed. Needs to be performed by credible and respected organization and publicly available for comment.
Indicator 2. Good. Should merge with previous HCV indicator, and clarify that it must be conserved. HCV assessment should be publicly available.

Worth noting and possible adjustment to wording. (PT)
ESIA here is proposed for new operations, to evaluate impacts. 4.2 deals with the need of consultation in all cases of potential negative impact for any type of project.
Guidance shall be provided. (e.g. IFAD, IFC have provided some guidance). (MG)

5.7.1 what does recognizable mean? There should be a clear guideline.
DG: Agree.

Guidance shall be provided (e.g. IFAD, IFC have provided some guidance). (MG)

Include a criterion on the conversion of high biodiversity areas after 30 November 2005 or January 2008. Currently no reference date is provided.

Reference date still to be defined. (PR)

Participatory means that women, youth, indigenous communities and the vulnerable in the affected and interested communities shall be consulted as well.
Participatory should at least mention that both men and women have to be consulted.
Consider expanding on ESIA as follows: For new large-scale projects, an environmental and social impact assessment, strategy, and impact mitigation plan (ESIA) covering the full lifespan of the project shall arise through a consultative process to establish rights and obligations and ensure implementation of a long-term plan that results in sustainability for all partners and interested communities. The ESIA shall cover all of the social, environmental, and economic principles outlined in this standard (= criterion 2a from the biofuels code).
Risk assessment should specify between different risks for men and women.
When looking at on and off site impacts consider adding: Special measures that benefit women, youth, indigenous communities and the vulnerable in the affected and interested communities shall be designed and implemented, where applicable. (= criterion 5b from the biofuels code). This allows us to look at gender and power relations in rural and indigenous communities.
After the risk assessment periodic monitoring is needed: For existing projects, periodic monitoring of environmental and social impacts outlined in this standard is required (= criterion 2b from the biofuels code). Gender expertise needs to be included when doing the assessment and the monitoring.
The ESIA shall include the identification of High Conservation Value Areas, biodiversity corridors, buffer zones, and ecosystem services; shall evaluate soil health; shall identify potential sources of air, water and soil pollution; shall evaluate potential impacts on water availability; shall cover a baseline social indicator assessment; shall include an economic feasibility study for all key stakeholders (both men and women); shall identify potential positive and negative social impacts including job creation and potential loss of livelihoods, specifying between men and women; shall establish any existing water and land rights.
Small-scale producers or cooperatives unable to perform ESIAs will need support and/or modified ESIAs.
‘Large-scale producers’ and ‘relevant stakeholders’ will be defined in the indicators, but will at least include men and women (= key guidance 2a from the biofuels code).

More comprehensive rewording of the criteria and detailed guidance to be provided taking into account suggestions. (MG)

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5.8.2 – Number of cases resolved versus number of cases brought through dispute resolution mechanisms
This indicator needs further clarification and a detailed description. At this point, it is not possible to access its feasibility or to comment on it.

Agree further work needed. Number of disputes provides indication of the quantity, but not on the “quality or depth” of problem to be solved. (MG)

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Indicators don’t address some of the aspects of the criteria (e.g. active engagement, transparency, participatory processes etc.) they only require a formal grievance/dispute resolution mechanism – which is a long way from a participatory active engagement with stakeholders. The 5% miss is arbitrary, consider whether the scale or the type of the grievance should play a role.

Indicator to be reviewed (MG)

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5.8.2 The duration of disputes on the public dispute settlement system (justice) are not controlled by the industry. Why was it included in the standard (by the word “legal”)? If it is not considered, the word legal should be removed. 
DG: I do not see where the duration of the disputes is discussed in the Standard.  Having a simple metric like they are proposing though is likely to not give a good enough picture, especially for long-standing disputes, or to gauge the seriousness/severity of any given dispute.  Not all disputes are equal in weight or impact.  More transparency overall is needed and more important.

Indicator to be reviewed (MG)

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Indicator 1. Should be in social principle.
Indicator 2. This belongs in social. Focus should be on process rather than percent resolved. There are many that may not be resolvable or resolved in a short period

Training is part of the basic to perform job and is essential for continuously improve.
Agree that process essential (MG)

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Active engagement and participatory consultative processes means more than grievance procedures or number of cases resolved. That seems a very narrow view. Consider the following: Sugar cane and biomass production shall contribute to the social and economic development of local, rural and indigenous peoples and communities (= criterion 5 of the biofuels code).
Add: Special measures that benefit women, youth, indigenous communities and the vulnerable in the affected and interested communities shall be designed and implemented, where applicable. (= criterion 5b from the biofuels code).
And add another criterion: Sugar cane production shall not impair food security (= criterion 6 of the biofuels code).
Consider changing the indicator to: A baseline social assessment of existing social and economic conditions and a business plan that shall ensure sustainability, local economic development, equity for partners, and social and rural upliftment through all aspects of the value chain shall be made. (partly taken from criterion 5a biofuels code; see also at guidance).
Add by whom the assessment is carried out. After the baseline assessment, monitoring needs to be included as well.
Add that participatory should mean consultation with men and women.
Look carefully at who (men / women) represents communities. Is the local population aware of the impact of their choice pro or contra sugar cane? Is there financial compensation or is long term alternative income generation offered? Compensation needs to be established participative, and is for both owners and users.
Consider adding this guidance: Large producers and processors shall work with local governmental and non-governmental agencies to ensure the proper application of this criterion. There should be measured improvements in social and economic indicators as set against the baseline and targets, in proportion to the scale and extent of the project and the region in which it is located. The ILO’s Decent Work Agenda is a recommended tool for assessing local impacts. The following best practices should be aimed for in the projects: local ownership of both men and women, local employment and livelihood opportunities, opportunities for the local labour force in the off-season to ensure stable local communities, diversification of crops if shown to improve local economic conditions of communities, training, value added products, credit facilities for local communities and small outgrowers (e.g. through micro credit schemes supported by buyers and/or financial institutions). Appropriate institutional structures should be developed, such as co-operatives that encourage and maximize local involvement and management (taken from 5a biofuels code).

All indicator to be reviewed (MG)

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This relates to the land and should be included along  the mills, a whole of industry approach

2

5.9 – Value added per ton of cane
Again, the calculation of the value added is complex and needs to be clearly defined. Methodologies can vary (for example: does it consider only direct inputs or are capital costs and/or land opportunity costs included?). Also, as noted before, it should be kept in mind that this calculation involves the use of strategically and commercially sensitive data for the mills.

Potential problems with release of financial data are possible. A notional value can if necessary be computed from data available in most sugar industries. Some Brazilian mills already disclose this information and more. (PR)

6

The calculation given for ‘value added’ is surely ‘profit?’  Is this promoting economic sustainability? (I guess it is ensuring their own business profit, but what is the effect on the economic sustainability of providers?)   What if profit is not the main motivation – is it OK to be breaking even if you are providing employment and supporting the community???
What about when the mill and agriculture are the same unit (e.g. owned by the same company).What about mills that produce several products? Affected by market prices?

Need to consider comments – maybe require alternative units. (PT)
Value added is not the same as profit. It is much easier to calculate than profit, as it is unaffected by different accounting standards. An organization creating value distributes that value to employees, the government (tax), shareholders and retains some for further investment. An organization which does not create enough value will not be sustainable. All products contribute to the value added. (PR)
Value added per tonne cane shows the viability of the agricultural operations. (PR)

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There is only mention of value added/tonne cane. That seems a very narrow view of economic sustainability. Change that into: Sugar cane production shall contribute to the social and economic development of local, rural and indigenous peoples and communities (= criterion 5 of the biofuels code).

As above (PT)

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Cannot see how Value added can be applied to Mill and Agriculture separately - surely should be applied to the combined operations?

As above (PT)
There is an interface between the growers and the mill; the cane is paid for and represents the revenue to the growing sector. (PR)

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How is it calculated? Why 3 as the indicator? Is it universally representative?

Will need to be defined in detail. (PR)

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Do we need a certification system that mandate a degree of profitability? Metric as proposed completely ignores invested capital. Suggest eliminating from the standard. Will create a perception of mandated margin in lieu of a free market system.
Another approach to encourage efficiency is (for sugar production) for farmers to be paid on RV as opposed to weight/tonnage.

Value added is not the same as profit. (PR)
Return on investment was rejected as an indicator, because of the reluctance to release required information, and because of the different methods of calculation 9e.g. using replacement value, original value or depreciated value). (PR)

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Terms in the theoretical recovery equation, and in the sugarcane and biomass yield equations, have not been adequately defined to the non-specialist.

Will be defined in Appendix (PR)

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Definition of subcontractor – better defined as supplier or contractor

OK  (MG)

Key

2

As indicated in 2.1, operators have to comply with conventions signed by the countries where they are operating. Hence, even if there is a wider list of conventions, they would not be affected. (MG)

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Add a reference to the U.N. Convention on the Elimination of All Forms of Discrimination against Women. The convention was adopted by the UN General Assembly on 18 December 1979 (resolution 34/180) and entered into force on 3 September 1981; and/or to the U.N. Declaration on the Elimination of Violence against Women. This resolution was adopted by the General Assembly on the report of the Third Committee (A/48/629). Resolution 48/104.

Ok  (MG)

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Appendix 2 can be updated with a list of conventions such as

Discrimination based on race, caste, origin, religion, disability, gender, sexual orientation, union or political affiliation, or age; no sexual harassment”

The definition of discrimination as per C111 will be provided clearly. (MG)

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