Feld vst report Burkna Faso RSB Smallholder Standard Systems June 2013 For more nformaton: Adenvronment Barentszplen 7 1013 NJ Amsterdam The Netherlands + 31 (0)20 686 81 11 nfo@adenvronment.org www.adenvronment.org Calcaterra Elsa EPFL Ecole Polytechnque Fédérale de Lausanne Energy Center Château de Bassenges - Staton 5 CH 1015 Lausanne Swtzerland elsa.calcaterra@epfl.ch http://energycenter.epfl.ch Photos Peter de Haan
Feld vst report Contents 1. Executve summary 3 2. Introducton 5 3. Objectve 5 4. The farmer groups 6 5. Feedback on the draft standards 7 2
1. Executve summary The feld vst to Burkna Faso had a threefold objectve: 1. Assess the feasblty and accuracy of the draft RSB standards for smallholder farmers 2. Assess the applcablty of the standard for group certfcaton 3. Assess the feasblty of Greenhouse Gas (GHG) data collecton for smallholder group certfcaton The feld vst to Burkna Faso s the thrd n a seres of 5 vsts carred out n developng countres n Asa, Afrca and Latn Amerca. It s the frst tme that the questonnare for GHG data collecton has been tested. Overall, the RSB standard for smallholder farmers s consdered both feasble and accurate for Jatropha farmers n the Barsalogho regon, 150 km north of the captal Ouagadougou. However, ndvdual smallholder farmers wll not be able to self-assess complance wth the RSB Smallholder Standard n the current form (RSB Smallholder Standard prncples, crtera and ndcator document and GHG questonnare), even f t were translated n French. It s doubtful f communty level groups could effectvely do ths wthout external support. The manager of the envronment program of Assocaton Impulson would be well qualfed as group manager and could assess complance wth the RSB Smallholder Standard and complete the GHG questonnare wthout encounterng major problems. Complance wth natonal and nternatonal labor laws (prncple 4) exsts or can be acheved wthn a reasonable perod. Complance wth nternatonal standards of occupatonal safety s not consdered feasble though. On the bass of the feld vst we would recommend that the group manager would be responsble for assessng complance wth the requrements of the RSB Standard document of ndvdual group members. Ideally, the group manager would desgn a smple form relatng to basc on-farm nformaton that can be flled n by the farmers. In dong so, the mportance of drect nvolvement of smallholder farmers rght from the start s made explct. The remanng nformaton would be provded by the group manager. The RSB smallholder standard for group certfcaton s found to be applcable. Assocaton Impulson (AI) -www.assocatonmpulson.org - could act as group manager and ths organzaton would be able to go through the certfcaton process n a relatvely short perod. At ths stage though, there s no real pull towards certfcaton, as there s no thrd party requrng certfed Jatropha or payng a premum for t. All Jatropha bought by AI s processed by the own organzaton and used for local electrcty generaton. The electrcty generaton and the grd are both managed by AI. Certfcaton could stll be relevant though: As a means of mprovng effcency at all levels n the supply chan When producton by farmers starts to exceed local demand and other outlets need to be found Potentally, as a guarantee when external commercal fundng would be needed to fnance expanson, e.g., f certfcaton could facltate access to credt. In ths plot, the group manager buys Jatropha seeds from the group of producers and processes these nto ol for local electrcty generaton. Ths process s not covered by the smallholder standard, as the sad standard s lmted to cultvaton only. Applyng the smallholder standard to Jatropha ol producton operatons would be cost-effectve from the group manager s perspectve, snce otherwse the group manager would need to apply a dfferent standard (the regular RSB Standard) for ther ol processng operatons. Costs of such a double certfcaton mght well be prohbtve. An overarchng queston wth regards to the smallholder standard becomes thus, whether ths process could be part of the smallholder scope of certfcaton. Ths may make sense, 3
snce otherwse the group manager would need to apply a dfferent standard to ther ol processng operatons than to the group of smallholder producers. The Group Manager would be able to carry out the GHG data collecton. Most farmers could partcpate n the data collecton f the questonnare were n the local language and smple enough; however, some farmers n ths plot were fully llterate and would not be able to fll out even a smple questonnare. The Group Manager would be able to run the RSB GHG Tool, but only n Ouagadougou where the nternet connecton s better. Land Use Change (LUC) could be dffcult to model, as t s usually lmted to the removal of bushes, whch does not have a drect translaton n the LUC categores lsted n the RSB GHG Tool. Some requrements n the standard are dffcult to assess wthout detaled local knowledge: ths ranges from the defnton of (local, regonal and global) conservaton values, ant-eroson best practces, replenshment capacty of the local water table, etc. If the judgment s left to the audtor, then they must be an expert n many dfferent dscplnes. If the judgment s left to the group manager, they may have to engage local experts, wth the subsequent expenses. There s also a queston of how contnuous mprovement should be judged. The GHG calculaton would not help n calculatng carbon credts on regenerated land. Developng an addtonal module that would facltate carbon credt calculatons wll probably be straghtforward. The fnancal benefts of the carbon credts could (partally) offset the cost of certfcaton and would thus enhance ts attractveness. Ths s partcularly mportant n stuatons - such as n the Burkna Faso - plot where there s no drect market pull for certfcaton. Pcture 1. Group portrat n the Jatropha nursery of Assocaton Impulson. Solar panels n the background are used to power the water pump 4
2. Introducton The Roundtable on Sustanable Bomaterals (RSB) s an nternatonal ntatve launched by the Swss Federal Insttute for Technology (EPFL) wth the goal to develop sustanablty standards for bofuels. Its current Standard (verson 2.0) s vald for all type of producers of bofuels and bomaterals. The RSB s now an ndependent organsaton, whle EPFL contrbutes to ts work through a number of projects. The RSB requres the same level of sustanablty from dfferent types of producers, but the path towards complance may dffer dependng on the sze of operatons. Wthout support, smallholders n less developed countres may have dffcultes n complyng wth the RSB standards. Smallholders have a specal mportance consderng the mpacts of Socal and Envronmental Standard Systems. Hence the need to adapt specfc parts of the RSB system to small-scale farmers and small feedstock producers n developng countres. Ths way, smallholder access to the market for sustanable bofuels can be assured. Adenvronment s advsng EPFL on the certfcaton of small-scale farmers and smallholders n developng countres, and the man objectves of the advsory servces are: Development of a defnton of small-scale farmer and smallholder that takes nto account regonal dfferences and addresses dfferent modes of organzaton; Development of specfc provsons for small scale farmers and smallholders for ncluson n the RSB Standard; these mght be dfferent from those that are already exstng, and should take nto account potental regonal/organzatonal specfctes of small scale farmers and smallholders; Development of a Group Certfcaton Polcy for smallholders n developng countres for the RSB Standard. Preparaton of a Gudance Document for Smallholders n developng countres Provson of recommendatons on how to ncrease access to certfcaton for smallholders. A seres of feld vsts s mplemented n order to assess the feasblty and accuracy of proposed adaptaton of RSB standards for small scale farmers. From June 1 - June 5 2013, Vctora Junquera (EPFL) and Peter de Haan (Adenvronment) vsted Jatropha growers n Barsalogho, Burkna Faso to test the RSB Smallholder Standard and Group Certfcaton Protocol. Ths document presents the most mportant fndngs of ths feld trp. Durng the same vst, a frst test of the GHG protocol was carred out. The outcomes of ths test are ncluded n ths report. 3. Objectve In developng the smallholder provsons, a set of general assumptons has been made. As the nature of the organzatonal structure, management and farm practces can dffer sgnfcantly; these assumptons are to be tested on the ground. The feld vsts do ths by assessng the feasblty and accuracy of the RSB standards for small scale farmers and smallholders n developng countres. The outcomes of the feld vsts are used as nputs for the fnalzaton of the delverables. The man questons to be answered through the feld study are outlned below. Smallholder organzatons a) Do the assumptons we make n developng the smallholder provsons ft the stuaton of Jatropha smallholder producton n Burkna Faso? 5
b) Would such schemes have an nterest n smallholder certfcaton or not? c) Is our understandng of a group n lne wth what we fnd? d) What crtera should be met by smallholder groups/organzatons to qualfy as RSB smallholders under the RSB Standard? e) How do the requrements of the standards ft wth the capactes of the smallholders and ther organzaton? f) What condtons and ncentves need to be n place to make RSB certfcaton nterestng for smallholders? Management capactes of Group Management g) Group Management capacty regardng Internal Management System, chan of custody montorng, data collecton. What s the ablty of the group manager - Assocaton Impulson n ths case - to reach out to members? Sustanablty mpacts h) Are the draft RSB smallholder provsons adequate to ensure sustanable feedstock producton? ) How are Jatropha plantatons developed and managed wth regards to sustanable practces? Reachng smallholders Standard for Group Certfcaton (Prncple 2) Is the standard for group certfcaton applcable? Would the group manager be able to put n place an adequate nternal management system and ensure ) contnuous mprovement ) product ntegrty ) nternal nspectons and v) record keepng? GHG data collecton (Prncple 3) Is GHG data collecton for smallholder group members feasble? Are GHG data collecton, management, recordkeepng and calculatons feasble for group management? 4. The farmer groups Pcture 2. Durng meetng wth representatves of farmers groups Assocaton Impulson (AI) s actve n the 4 northern Departments of the Sanmatenga Provnce n Burkna Faso. In 2010, AI started the Jatropha program whch has quckly become the most mportant component of ts Envronment program. Between 2010 and 2012, approxmately 225,000 plants (correspondng to 560 ha) have been dstrbuted free of charge to partcpatng farmers n 20 vllages. Snce 2010, AI also carres out tranng on agrcultural technques and harvestng. Approxmately 800 farmers partcpate n the Jatropha program voluntarly and are loosely organzed. Vllages n Burkna Faso have local development counselors, the Consellers Vllageos de Développement. Rather than create a separate structure, AI uses these counselors to ensure an effectve lnkage between the partcpatng farmers n ther group and the program. Wth the growth of the operatons, AI ntends to create dedcated groups of Jatropha growers n the comng years. 6
5. Feedback on the draft standards In ths secton we provde feedback on the draft RSB Smallholder Standard based on the Burkna Faso plot fndngs. Prncple 1: Legalty P1 C1.a Legalty: Bofuel operatons shall follow all applcable laws and regulatons. Bofuel operatons shall comply wth all applcable laws and regulatons of the country n whch the operatons occurs There s an up-to-date overvew of natonal laws and regulatons applcable to the operatons of the group management and members and an acton plan to support producers to towards complance. Bofuel feedstock producton operatons comply wth applcable laws and regulatons. The group members are aware that natonal laws are applcable to ther work, for example n the area of land acquston and the use of chemcals. The groups are not necessarly aware of all the applcable laws. There s no lst of laws and requrements, nor s t clear where ths nformaton should be sourced from and how t would be kept up to date. Smple gudance on applcable laws would help wth complance. Smallholders may be operatng outsde the law wthout beng aware. As was already noted durng the South Afrca feld vst, t s crucal to consder what level of legal complance should be requred pror to obtanng the frst certfcate and f t may be an opton to requre full complance over a perod of tme accordng to a progressve approach. There s a queston of whether the overvew of natonal laws should be n wrtng, whch could be very cumbersome for the group manager to develop. We suggest that gudance should ndcate that copes of the laws are not necessary but an overvew on paper of the most relevant legal requrements should be avalable (even f t s a lst wth bullet ponts) Prncple 2: Plannng, Montorng and Contnuous Improvement P2 C2.a C2.c Plannng, Montorng and Contnuous Improvement: Sustanable bofuel operatons shall be planned, mplemented, and contnuously mproved through an open, transparent, and consultatve mpact assessment and management process and an economc vablty analyss. Bofuel operatons shall undertake an assessment to assess mpacts and rsks and ensure sustanablty through the development of effectve and effcent mplementaton, mtgaton, montorng and evaluaton plans. The Group Management or external agent conducts a Smplfed Socal and Envronment Rsk Assessments of exstng and possble future mpacts of member operatons s conducted. There are proven efforts of achevng partcpaton of relevant stakeholders and local experts as well as group members. An acton plan exsts to reduce negatve mpacts as dentfed n the SSERA. The acton plan ncludes targets, actvtes and a montorng and evaluaton system. Groups whose aggregate membershp plan to expand total holdngs by more than XXX ha n any one year must undertake a comprehensve and partcpatory ndependent socal and envronmental mpact assessment as defned by the RSB Standard 2.0, Crteron 2a & 2b. Bofuel Operators shall mplement practces that reflect a commtment to long-term economc vablty. 7
Group members are aware of the long-term economc vablty of ther operatons and apply best practces to enhance long-term economc vablty. Farmers have no experence n mpact assessments and rsk assessments. AI systematcally plans and montors the ongong operatons, but would need gudance on how to conduct an SSERA, ncludng on how to select local experts and stakeholders, and the frequency wth whch such assessments should be carred out. Some farmers record nputs/costs and profts, but not all of them do. In some cases, farmers lack the capacty to do ths. Wth lmted external support, Assocaton Impulson would be able to take on the role of Group Management as defned under pont II of the Standard for Group Certfcaton. The Jatropha farmers already fulfll most condtons as stpulated under pont III and full complance would be straghtforward. The current Internal Management System of AI can easly be expanded to comply wth the Group Certfcaton Standard. Current degree of complance: a) Group structure at vllage level s rudmentary and needs to be further developed, ncludng a degree of formalzaton ncludng rules and regulatons related to pont b) up to and ncludng pont h) b) Approval and termnaton of membershp - members are free to jon and leave c) Product ntegrty - n practce the chan of custody s there, as AI s the only buyer of the produce n the regon. Chan of custody trackng could be ntroduced when relevant d) Rsk assessment - not part of the management system yet. e) Group member record keepng requrements - excellent record keepng at central level. Record keepng at local level to be expanded when operatons ncrease f) Internal nspecton system - not part of the management system yet g) Sanctons and appeals - not part of the management system yet h) Dspute settlement - not part of the management system yet Improvement currently takes place n a more or less nformal way. Group management s expected to be able to put n place, and mplement, procedures for contnuous mprovement as defned under Pont V plan of the standard. The same would apply to the procedures needed to ensure product ntegrty and nternal nspectons. Assocaton Impulson s a result orented organzaton that s well organzed and run effcently. Wth lmted external support, t would be able to go through the certfcaton process and mantan the certfcaton over the years. Ths very postve assessment must be put n perspectve though: AI s exceptonally well run, and the fndngs can therefore not automatcally be translated to other comparable organzatons n the sub-regon At ths stage though, there s no real pull towards certfcaton, as there s no thrd party requrng certfed Jatropha or payng a premum for t. All Jatropha bought by AI s processed by the own organzaton and used for local electrcty generaton. The electrcty generaton and the grd are both managed by AI. The management of AI consders that certfcaton could, n due tme, stll be relevant though: o As a means of mprovng effcency at all levels n the supply chan o When producton by farmers starts to exceed local demand and other outlets need to be found o As a guarantee when external commercal fundng would be needed to fnance expanson 8
Prncple 3: Greenhouse Gas Emssons P3 C3.b Greenhouse Gas Emssons: Bofuels shall contrbute to clmate change mtgaton by sgnfcantly reducng lfecycle GHG emssons as compared to fossl fuels. Lfecycle GHG emssons of bofuel shall be calculated at group level, usng the RSB lfecycle GHG emsson calculaton methodology Group management organzes the collecton, aggregaton and documentaton of nput data as requred by the RSB lfecycle GHG methodology from members to calculate lfecycle GHG emssons. It provdes access to ths data to ther buyer of RSB certfed produce. To ncrease the economc feasblty of data collecton, the group management may use the samplng method as descrbed n the gudelnes on. Group management Group management already makes substantal effort n gatherng specfc data from each of ther group members and could gather GHG data from any of the group members. However, group management already dedcates a substantal amount of tme for data gatherng and could not handle a substantal ncrease n requred data gatherng volumes. Therefore, samplng s recommended,.e., gatherng data and conductng calculatons based on a sample of the total group sze. The test of the questonnare dd not reveal major problems. However, the sectons on chemcal fertlzers and pestcdes were not tested as farmers dd not use these. Group management already has a database wth producer nfo and, deally, all or most of the data (GHG and other) would be ntegrated n the same database (e.g., Excel sheet). That way, GHG calculaton would only be a lmted management burden. Ths would requre adjustng the Excel spreadsheet. The GHG questonnare, Excel spreadsheet and all accompanyng documents would have to be made avalable n French Some unts are not evdent, such as kg of manure (they use volume unts). It would be useful f the Excel sheet (and questonnare) were slghtly modfed so that the data can be gathered n commonly used unts (feet, tnes etc.) and converted by the Excel sheet nto the relevant unts for the calculaton (kg, ha, etc.) It proved mpossble to upload the RSB GHG n the local offces n Barsalogho due to weak nternet connecton. It took over 25 mnutes just to upload the frst page of the Tool. Thus, the GM would need to run the Tool n Ouagadougou whch s feasble f t s only requred once per year. GM would be nterested n obtanng carbon credts for the rehabltaton of degraded land, even though ths process s complex and would nvolve addtonal management capacty. The current verson of the RSB GHG Tool does not allow the calculaton of carbon credts. Facltatng access to carbon markets would defntely be a plus of certfcaton schemes; ths would requre, among other thngs, developng a tool or gudance that would help the GM conduct the necessary calculatons and documentaton. Smallholders Many smallholders are llterate. In most households though, younger persons wll be avalable who can read and wrte. Even so, lteracy levels are low and some would not be able to complete a questonnare, even f t were smplfed The questonnare would need to be avalable n French or, deally, n Moree (local language) Smallholders do not use chemcal fertlzers or pestcdes; they use manure and can quantfy amounts n terms of volume. Land Use Change s dffcult to estmate wth the categores currently present n the tool. Some Land use Change takes place occasonally where bushes (but not trees) are removed to 9
make room for crops. Ideally, the tool would be able to record how many bushes were removed, but currently t does not have that feature. Samplng s recommended to allevate data gatherng and management efforts. The GM would be able to fll out questonnare upon ntervew wth farmers; but not all farmers would be able to do so. GM would be able to fll out GHG Excel sheet but preferably, t would be n French. The RSB GHG Tool can be run, but only n Ouagadougou where nternet connecton s better. It s recommended to customze unts of Excel sheet and questonnares for dfferent smallholder groups, snce the unts are dfferent from those used on the feld. Customzaton would be a relatvely easy thng to do. Land Use Change may be dffcult to model. Usually, Land use Change s lmted to removng bushes; the shrublands category may be the closest ft. It would be recommended that the RSB provde gudance to the GM on whether the shrubland category s adequate, and whether the acreage should be adjusted for carbon content. Burnng of felds no longer takes place. The GHG calculaton would not help the GM n the process of calculatng carbon credts on regenerated land. It s suggested to develop an addtonal module or gudance that would facltate ths process as t would enhance the attractveness of certfcaton. Prncple 4: Human and Labor Rghts P4 C4.a C4.b C4.c C4.d Human and Labor Rghts: Bofuel operatons shall not volate human rghts or labor rghts, and shall promote decent work and the well-beng of workers. Workers shall enjoy freedom of assocaton, the rght to organze, and the rght to collectvely bargan. Workers shall have freedom of assocaton, the rght to organze, and the rght to collectvely bargan. In countres, where the law prevents collectve barganng or unonzaton, there shall be no nterference wth workers own efforts to set up representatonal mechansms. The effectve functonng of labor organzatons s not opposed and there shall be no dscrmnaton to members or representatves of labor organzatons. No slave labor or forced labor shall occur There shall be no forced, compulsory, bonded, traffcked or otherwse forced labor. No chld labor shall occur, except on famly farms and then only when work does not nterfere wth the chld s schoolng and does not put hs or her health at rsk Chldren of the age of 14 and under (or below the legal mnmum age f ths s hgher) are not employed n group management or members operatons. Where permtted by law, chldren between 12 and 14 years of age can work part tme on famly farms, only f they are famly members or neghbors n a communty where chldren have tradtonally helped wth agrcultural work. Work by chldren of group members s only done under adult supervson and does not nterfere wth ther educatonal, socal or physcal development. Ther work day ncludng schoolng, transport and work does not exceed 10 hours. Workers below 18 years of age do not perform hazardous work, whch s work n dangerous, unhealthy or unsafe condtons that could result n them beng klled, njured or becomng ll. Workers shall be free of dscrmnaton of any knd, whether n employment or opportunty, wth respect to gender, wages, workng condtons, and socal benefts. 10
C4.e v v v C4.f v v C4.g There shall be no dscrmnaton on workers n hrng, remuneraton, benefts, access to tranng, promoton, termnaton, retrement or any other aspect of employment, based on race, color, gender, relgon, poltcal opnon, natonal extracton, socal orgn, sexual orentaton, famly responsbltes, martal status, unon membershp, age or any other condton that could gve rse to dscrmnaton. Workers shall not be subjected to corporal punshment, mental or physcal oppresson and coercon, verbal or physcal abuse, sexual harassment or any other knd of ntmdaton. Workers' wages and workng condtons shall respect all applcable laws and nternatonal conventons, as well as all relevant collectve agreements. Workers (permanent and temporary) are pad at least the gross wages that comply wth natonal legslaton and sector agreements, whchever s hgher. Where a mnmum wage s absent, the wage pad for a partcular actvty shall be negotated and agreed on an at least annual bass wth the worker. For pecework (pay based on the output of work provded rather than hours), the pay rate must allow workers to earn at least the legal mnmum wage or ndustry standards, whchever s hgher, based on an eght-hour workday under average condtons. Wages shall be provded on a regular bass n cash or n another form acceptable to workers. No deductons from wages as a result of dscplnary measures are made. The maxmum number of regular hours worked per week must not exceed 48. Workers may work overtme whch shall be voluntary and pad at least equal to regular work, but total workng hours shall not exceed 80 per week. Condtons of occupatonal safety and health for workers shall follow nternatonally-recognzed standards. All workers are provded wth and regularly use adequate personal protectve equpment to protect them from all occupatonal health and safety hazards assocated wth ther respectve jobs. Accdent and emergency procedures and measures (ncludng frst ad, fre contanment procedures, and spll responses) are n place at all operatons and smallholder farms n accordance wth the dentfed rsks n the Smplfed Socal and Envronment Rsk Assessment. Workers follow safety nstructons on the storage, handlng, use, dsposal of hazardous substances and waste and follow emergency procedures followng accdental spllages. Workers shall have access to drnkng water. Any housng provded by the group management or members for permanent or temporary workers shall be bult and mantaned to ensure good santary, health, and safety condtons and shall have access to adequate drnkng water facltes. Operators shall mplement a mechansm to ensure the human rghts and labor rghts outlned n ths prncple apply equally when labor s contracted through thrd partes. Members are aware of the rghts of sub-contracted workers and occupatonal health and safety requrements and these sub-contracted workers confrm these rghts. Durng the feld vst, t was not found that there would be any conflct between Prncple 4 and labor laws of Burkna Faso. Permanent workers do not exst n rural areas of Burkna Faso. Rather, laborers are hred occasonally n tmes of peak demand for labor. Ths s lmted to a few days per year durng feld preparaton, weedng and harvestng. Pay per task would be equvalent to the mnmum wage. Very often, labor s provded n the form of entrade whereby farmers take turns n workng on neghbors felds. In those stuatons, tradtonal rules apply. 11
Freedom of assocaton, the rght to organze and the rght to collectvely bargan are well recognzed and respected n Burkna Faso. No forms of forced labor are known. The labor law of Burkna Faso 1 dstngushes between chldren and adolescents. Every person under the age of 18 s consdered a chld, whle chldren under 16 years of age are not allowed to work. Adolescents are aged between 18 and (up to and ncludng) 20 years of age. Artcle 149 of the Labor Law stpulates that chldren and adolescents are only allowed to carry out work that can have no negatve mpacts on ther further development or reproductve capactes. The Labor Law s completed by a lst of actvtes that chldren are not allowed to carry out 2. Ths lst ndcates the maxmum weght that chldren are allowed to carry or push (wheelbarrow). Wth regards to work n agrcultural excludes the handlng of chemcal fertlzer and phytosantary products as well as the operaton of motorzed farm mplements. In legal terms, the poston of adolescents s the same of that as women. Artcles 82-88 of the Labor Law, stpulate the maxmum number of hours that may be worked. The Labor Law and tradtonal practce n the Barsologho regon show a number of dfferences. Tradtonally: A person s consdered an adult when reachng the age of 17 3. Chldren of 15 years are allowed to do farm work under entrade rules. When employed, chldren are expected to perform ther work as f they were adults. Durng the ntervews n the feld t was stressed that employment of chldren was very much an excepton. Typcally, temporary workers are 30 years and over. Condtons of occupatonal health and safety are relatvely straghtforward as farmers do not use any chemcals or fertlzers, be t for Jatropha cultvaton or otherwse. Some occupatonal safety concerns reman though, and there s hardly any consderaton of those. In a country where most people do not wear shoes for fnancal reasons, t s smply mpossble to apply nternatonally recognzed standards for occupatonal safety related to protectve clothng and equpment used. Occupatonal health consderatons are also of mportance n ndustral settngs,.e., n the processng of the Jatropha seeds for the producton of ol. In ths plot, AI conducted the crushng and fltraton operatons. An overarchng queston, especally wth regards to ths prncple, s whether the ol producton should not also be part of the smallholder certfcaton scope. Overall ths prncple s partally understood. Complance wth natonal labor laws exsts or can be acheved wthn a reasonable perod Ths would nvolve ensurng that chldren under 16 are not employed and that chldren and adolescents wll only be gven work that can have no negatve mpacts on ther further development or reproductve capactes. Complance wth nternatonal standards of occupatonal safety s not feasble. Prncple 5: Rural and Socal Development 1 Lo No 28-2008/AN portant Code du Traval au Burkna Faso 2 Décret No 2009-365/PRES/PM/MTSS/MS/MASSN/ portant détermnaton de la lste des travaux dangereux nterdts aux enfants au Burkna Faso. JO no 26 du 25 jun 2009 3 It s to be noted that there are consderable dfferences between ethnc groups n Burkna Faso related to the ages at whch a person s deemed to be adult. The Peulh (Fulan) who lve just north of the project regon consder a boy adult at age 15 and a grl at age 14. 12
P5 In regons of poverty, bofuel operatons shall contrbute to the socal and economc development of local, rural and ndgenous people and communtes. The draft standard does not nclude requrements n ths prncple as t consders smallholders as the benefcares of ths prncple. However, the partcpants expect the bomass project to contrbute to rural and socal development. Prncple 6: Local Food Securty P6 C6.b Food securty: Bofuel operatons shall ensure the human rght to adequate food and mprove food securty n food nsecure regons Bofuel operatons shall enhance the local food securty of the drectly affected stakeholders. Group members are aware of the rsks n terms of food securty of swtchng ther entre farmland nto bofuel producton and are aware of croppng models whch nclude the producton of food where t s an economc vable opton. Barsalogho s the northernmost part of the Moss Plateau of Burkna Faso. The plateau s densely populated and the latertc sols are degraded. Recurrent food shortages are most marked n the Northern parts of the plateau. Jatropha n Barsalogho s usually grown n mxed croppng systems; usually Nébé beans or groundnuts, but also wth Pearl Mllet, the man food staple. Assocaton Impulson provdes gudance to the farmers wth respect to plantng methods. For sol of average qualty, the recommendaton s to plant Jatropha n a 5x5 grd, where each plant s separated by 5 meters from the next. A food crop s planted n between the rows of Jatropha. In severely degraded land, Jatropha s mono-cropped usng the 5x5 format. Jatropha can also be used as a hedge ( hae vve ), n whch case AI recommends plantng t n a 1x1 format. Pcture 3. Jatropha plantaton n 5x5 grd. Plantng started n 2010 and farmers do not yet report any yeld decrease n croppng as a result of the nterplantng wth Jatropha. Reference (no source provded) s made to a study that would even 13
pont towards an ncrease of the yelds of crops grown n assocaton. Close montorng of yeld development over the years s recommended. As the regon has recurrent food shortages, montorng of the mpact of Jatropha cultvaton on food securty s crucal. As yet, there are no ndcatons that bofuel producton s negatvely affectng food producton. In ths context, the group manager s role was crtcal n ensurng food securty, gven ther recommendaton to use Jatropha only as a double-crop or as a hedge, lmtng ts cultvaton as a monoculture to severely degraded land. In ths case, the group management went beyond the requrement n the standard: the requrement that farmers are aware of rsks and are aware of croppng models whch nclude food producton may fall short of ensurng food securty and t could best be requred that bo-energy be produced n conjuncton wth food where feasble. Prncple 7: Conservaton P7 C7.a v v C7.e Conservaton: Bofuel operatons shall avod negatve mpacts on bodversty, ecosystems, and conservaton values Conservaton values of local, regonal or global mportance wthn the potental or exstng area of operaton shall be mantaned or enhanced. There shall be a map or a lst of areas wth conservaton values of global, regonal or local mportance or that serves to mantan or enhance such conservaton values. Members are aware of these areas. Areas defned under requrement C7.a. shall not be converted after the 1st of January 2009, or earler as prescrbed by other relevant nternatonal standards. Areas defned under requrement C7.a. shall only be used f adequate management practces mantan or enhance the dentfed conversaton values (e.g. sustanable bomass harvestng). Where necessary, buffer zones shall be protected, restored, or created to avod negatve mpacts from bofuel operatons on areas defned under requrement C7.a. Huntng, fshng, ensnarng, posonng and explotaton of rare, threatened, endangered and legally protected speces shall not occur on the bofuel feedstock producton stes, related buffer zones and set-asdes. Bofuel operatons shall prevent nvasve speces from nvadng areas outsde the operaton ste. Members wll not use any speces prohbted n the country of operaton and recorded as hghly nvasve under smlar condtons (clmate, local ecosystems, sol types, etc.) n the Global Invasve Speces Database (GISD). If other nvasve speces are used, members wll have adequate measures to prevent and mtgate the rsk of nvason durng cultvaton, harvestng, processng, transport and trade. Some local groups operate n areas borderng wth gazetted (= offcally regstered) forests, usually wooded savannah and vestges of rparan forest. All ndvduals know the borders of the gazetted forests and no cultvaton takes place wthn these areas. There are no buffer zones surroundng the forest reserves. Outsde these areas, t may be problematc to assess conservaton values of local, regonal and global mportance, and especally to map them. Large and valuable tree speces (such as Shea, Ballantes, and Baobab trees) are not removed when clearng land. However, bushes are removed. It would be dffcult to say whether n removng such bushes, conservaton values are mantaned; or 14
alternatvely, t s dffcult to prove that n clearng the land, no conservaton values are lost. Hence, t would be useful f ths requrement were nterpreted for local context. A queston that arses s who should make such a determnaton. Another queston s whether the group manager should keep records of how conservaton values are beng mantaned (see ndcator ). On-farm bofuel cultvaton s lmted to Jatropha, whle lmted wld harvestng of the frut of the Ballantes tree also takes place. Jatropha s not consdered an nvasve speces and has been present n the country for a very long tme. Conservaton was found to be a well understood and unproblematc concept as long as t s lnked to protected areas. Assessng and mappng conservaton values outsde offcally protected areas may be dffcult for the group manager and would probably requre expert advce. The populaton of the regon tradtonally practces sol conservaton and productve trees (.e. for human or anmal use or for mantanng sol fertlty through ntrogen fxaton) are protected. Jatropha s not consdered an nvasve speces. Prncple 8: Sol P8 C8.a v Bofuels operatons shall mplement practces that seek to reverse sol degradaton and/or mantan sol health. Operators shall mplement practces to mantan or enhance sol physcal, chemcal, and bologcal condtons. Members mplement avalable and economcally vable best practces to avod sol eroson (e.g. crop rotaton, drect plantng, mantanng vegetatve ground cover, terracng, mantanng or creatng tree hedges, and the avodance of land clearance on senstve or hghly erodble sols, especally on steep slopes). Members mplement avalable and economcally vable best practces to mantan or enhance sol organc matter n ther operatons. Ths also mples that the use of agraran and forestry resdual products for feedstock producton, ncludng lgnocellulosc materal, shall not be at the expense of long-term sol stablty and organc matter content. Members mplement practces to mnmze sol compacton. Members mplement practces to mnmze the rsk of fre and the effects of wnd eroson (e.g. mantenance of approprate natural barrers). Sol eroson, especally wnd eroson, s a major concern n the regon. Partcpants apprecate the mportance of mantanng and mprovng sol condtons. Some farmers have taken correctve acton at ther own expense, usually n the form of stone rows along contour lnes and lve hedges. The cost of certan ant-erosons measures tends to be a bottleneck to some farmers. In some cases, Jatropha s used to rehabltate extremely degraded sols. Whle plants grow slowly, farmers clam that Jatropha s practcally the only speces survvng n these lands apart from Ballantes (an endemc tree). Assocaton Impulson wshes to promote land husbandry systems n whch Jatropha s used n strengthenng contour bunds, as lve hedges, etc. 15
To a large extent farmers n ths plot already comply wth the requrements of ths prncple, out of necessty, snce fertlzers are not economcally feasble and they cannot afford to lose the fertlty of ther sols. To an extent, t s the agronomcal expertse and advce of the group manager that contrbutes to proper sol management. In the absence of detaled local agronomcal knowledge, t would be dffcult for an audtor to judge whether best practces to avod sol eroson are beng mplemented by the group. Jatropha has the potental to be ntegrated n sustanable land use management. Group members have tradtonally mplemented practces that contrbute towards mantanng sol fertlty, though wth some extra effort, these could be mproved. Perhaps certfcaton could contrbute towards mprovement n ths sense. It would be dffcult for an external audtor wthout local agronomcal knowledge to judge whether best practces are beng mplemented. Pcture 4. Jatropha planted on heavly degraded land as part of land rehabltaton effort Prncple 9: Water P9 C9.a C9.c Bofuel operatons shall mantan or enhance the qualty and quantty of surface and ground water resources, and respect pror formal or customary water rghts. Bofuel operatons shall respect the exstng water rghts of local and ndgenous communtes. The use of rrgaton water shall not be at the expense of the water needed by the communtes that rely on the same water source(s) for subsstence. Water resources under legtmate dspute shall not be used for bofuel operatons untl any legtmate dsputes have been settled through negotated agreements wth affected stakeholders. Formal or customary water rghts shall be respected. Bofuel operatons shall not contrbute to the depleton of surface or groundwater resources beyond replenshment capactes. 16
C9.d Irrgaton water for bofuel feedstock producton shall not be wthdrawn beyond replenshment capacty of the water table, watercourse, or tank from whch the water comes. Irrgated bofuel feedstock shall not be establshed n long-term freshwater-stressed areas, unless the mplementaton of: a. good practces, or, b. an adequate mtgaton process that does not contradct other requrements n ths standard ensures that the water level remans stable. Members shall not wthdraw water from natural watercourses to the extent that t modfes ts natural course or the physcal, chemcal and bologcal equlbrum t had before the begnnng of operatons. Bofuel operatons shall contrbute to the enhancement or mantanng of the qualty of the surface and groundwater resources. Bofuel feedstock producton shall not occur on a crtcal aqufer recharge area wthout a specfc authorzaton from legal authortes Adequate precautons shall be taken to contan effluents and avod runoffs and contamnaton of surface and ground water resources, n partcular from chemcals and bologcal agents (e.g. adequate buffer zones of natural vegetaton). Jatropha cultvaton s exclusvely ranfed. Farmers do not report any water competton between Jatropha and other crops grown n the mxed croppng systems. Rather, Jatropha would help nfltraton and reduce loss of organc materal by reducng wnd eroson. Farmers cted eucalyptus as an example of a crop that largely competes wth nearby crops for water and nutrents, and specfcally stated that Jatropha dd not result n ths competton, but rather seems to enhance producton of double crops. Prncple 10: Ar P10 Ar polluton from bofuel operatons shall be mnmzed along the supply chan. C10.a Bofuel operatons shall avod and, where possble, elmnate open-ar burnng of resdues, wastes or byproducts, or open ar burnng to clear the land. If open-ar burnng of leaves, straw and other agrcultural resdues takes place, a plan shall be put n place to phase out wthn three years followng certfcaton. There s no open-ar burnng of agrcultural resdues, wastes or by-products, or open-ar burnng for land clearng. Tradtonal bush fres durng the dry season - to promote growth of grass for cattle - are no longer practced n the regon. Some lmted burnng of agrcultural resdues contnues to take place though. Ths would have to be replaced by compostng to comply wth the standard. To what extent should the lmted burnng of agrcultural resdues be elmnated, and for what reason? The burn ban n the RSB Standard was nsttuted wth sugarcane n mnd, where largescale burnng leads to serous deteroraton of local ar polluton. Compostng s a sensble soluton (though from a GHG emssons perspectve, t may not be necessarly much better than burnng), but t requres gatherng the resdues and buldng a compostng receptacle. In the case of very small volumes of agrcultural resdues, the queston arses of whether the burnng ban and mandatory phase-out make sense, and whether the extra effort of gatherng the resdues (f any extra effort s made) warrant the benefts. Burnng of resdues could be consdered acceptable from an agrcultural pont of vew as resdues may contan sources of pests and dseases Prncple 11: Use of Technology, Inputs and Management of Waste 17
P11 C11.b v v C11.c C11.d v v v v v x The use of technologes n bofuel operatons shall seek to maxmze producton effcency and socal and envronmental performance, and mnmze the rsk of damages to the envronment and people. The technologes used n bofuel operatons ncludng genetcally modfed: plants, mcro-organsms, and algae, shall mnmze the rsk of damages to envronment and people, and mprove envronmental and/or socal performance over the long term. There shall be no use of GMOs n areas where ths s forbdden by law. Where GMO are used, group management should consult responsble authortes to ensure that the group s aware of any rsk and how to mtgate those rsks. The use of genetcally modfed organsms shall follow relevant natonal or nternatonal gudelnes, laws and agreements, crop-specfc stewardshp systems, and local and communty coexstence agreements or understandngs. Members usng GMOs shall take measures to prevent mgraton of genetcally modfed materal and shall cooperate wth neghbors, regulatory and conservaton authortes, and local stakeholders to mplement montorng and preventatve measures. Crop-specfc and technology-specfc mtgaton strateges shall be utlzed. For new operatons, members shall use ndgenous crops whenever alternatve crops reduce yeld and/or envronmental and/or socal performance compared to ndgenous crops. Mcro-organsms used n bofuel operatons whch may represent a rsk to the envronment or people shall be adequately contaned to prevent release nto the envronment. In no case shall genetcally modfed mcro-organsms or any mcro-organsms that pose a rsk (pathogenc, mutagenc, contamnant, etc.) to human health or the envronment be released outsde the producton unt. Any such organsm used shall be destroyed or adequately neutralzed (.e. loss of any potentally hazardous character) before beng dsposed of. Good practces shall be mplemented for the storage, handlng, use, and dsposal of chemcals The group management mantans a lst of all chemcals recorded n the: WHO s 1a and 1b lsts Annex III of the Rotterdam Conventon Stockholm Conventon on Persstent Organc Pollutants (POPs) Group management mantans and updates a lst of all chemcals or bologcal agents used on certfed member farms. The lst s accessble by the publc on request made to the group management No chemcals that are recorded on the WHO s 1a and 1b lsts shall be used. The use of chemcals recorded n Annex III of the Rotterdam Conventon and n the Stockholm Conventon on Persstent Organc Pollutants (POPs) shall be lsted (type and annual volume used) and a plan to phase out any such chemcal over the three years followng certfcaton shall be descrbed. There shall be no use of chemcals recorded n Annex III of the Rotterdam Conventon and n the Stockholm Conventon on Persstent Organc Pollutants (POPs). Good practces for the storage, handlng, use, and dsposal of chemcals as promoted by the group management shall be followed Contaners for chemcals are washed and dsposed of n an envronmentally approprate way. Chemcals are dsposed, recycled or destroyed n a manner that mnmzes the rsk of accdents and potental negatve mpacts on human health and on the envronment. Durng transportaton of chemcals to and wthn the operatons health, envronmental and safety precautons to reduce the rsk of accdents or splls are mplemented adequately n relaton to the potental rsk (e.g. safely transported usng approprate equpment) 18
Assocaton Impulson solely uses seeds that are collected from plants growng around vllages. These plants are consdered well adapted to the condtons of the regon and therefore desrable. The smallholders do not use mcro-organsms, fertlzer or chemcals. Therefore, artcles C11c and C11d are not applcable. On the whole, Prncple 11 does not currently apply to the smallholders. Parts of Prncple 11 would be applcable to the ol producton operatons (crushng and fltraton) conducted by AI at the crushng faclty. Hence agan the queston arses of whether such operatons should not also be part of the scope of certfcaton. Prncple 12 - Land Rghts P12 C12.a C12.b Bofuel operatons shall respect land rghts and land use rghts. Exstng land rghts and land use rghts, both formal and nformal, shall be assessed and establshed. The rght to use land for bofuel operatons shall be establshed only when these rghts are determned. Group members can show evdence of ther rght to use the land ncluded n the scope of certfcaton. Land under legtmate dspute shall not be used by group members untl any legtmate dsputes have been settled and negotated agreements wth affected land users. Ths covers formal and customary (tradtonal) land rghts and land use rghts. Where there are land dsputes between group members or group members and the local communty, the group management establshes mechansms to address and solve those dsputes Land acquston of bofuel feedstock producton shall be based on voluntary relnqushment of rghts by prevous land users or owners and approprate compensaton. No nvoluntary resettlement and coercon to alter exstng land rghts or land use rghts shall be allowed for bofuel feedstock producton. Where land rghts and land use rghts are voluntarly relnqushed, and/or acqured on a wllng seller-wllng buyer bass, local people shall be farly, equtably and tmely compensated. Compensaton for voluntary relnqushment shall nclude approprate balancng measures needed to preserve the ablty of the persons concerned to sustan ther lvelhoods n an autonomous and dgnfed manner. Access to land s based on tradtonal law, whereby land s gven n loan. Dfferent plots of land wll have a dfferent status, wth land holdngs closest to the farm havng a permanent character, and other felds ( champs de brousse ) beng less permanent. Dsputes are usually settled by tradtonal landlords ( chef de terre ). Plantng of perennal crops can only be done by household heads on the more permanent plots. As most households n the regon are male headed, there are only very few female Jatropha farmers. Whle Assocaton Impulson wshes to promote equtable development, farly lttle seems to be acheved n ths respect n the past 3 years. More emphass on affrmatve acton s recommended Access to land s based on a well functonng tradtonal law system and usually allows for the plantng of Jatropha. Female farmers tend to have dffculty n obtanng the rght to grow perennal crops. 19