Comment Log Display

Ladies and Gentlemen,

Thank you for the opportunity to participate in this stakeholder
consultation on the planned addition to the LCFS. We very much
appreciate this opportunity. We are supporting the additional
requirements for low carbon fuels as described in the draft
document. In our view, this step is very important and will help to
strengthen the program and its credibility in the long term. To
further strengthen this initiative, we would like to recommend the
following aspects:

- We think that it is helpful to set out more detailed guidelines
for social and environmental criteria for the cultivation of
sustainable feedstocks on farm level, e.g. to describe "good
agricultural practices" or "best practice" for plant protection
product application, working security, social standards, etc.
Further, it would be important to have criteria for the long-term
maintenance of soil fertility, as this is an essential factor for
the long-term maintenance of production capacity and sustainability


- Clearer guidance on the verification process for farms would be
beneficial, especially the option for group sampling on farm level
to prove compliance with the set out requirements would help
farmers to minimize audit efforts.

- Biodiverse land areas as well as peat and wetlands should be
protected as those areas are crucial for preserving biodiversity.
They should be "fully" protected if not used for agricultural
production in the last years, or at least restrictions on their use
should be defined to preserve them.

- We think that it would be beneficial to cooperate with
established certification schemes. The Board can implement a
process for the recognition of qualified certification schemes who
then cooperate with certification bodies to conduct the
verification processes in the future. This set-up would be helpful
for the Board, as it ensure a credible verification process for the
set out requirements as it helps to:

a) establish a "triangle" between the certification bodies,
economic operators and the schemes with clear roles and
responsibilities ("balance of power"), to ensure a global,
transparent and independent verification process, a conflict of
interest-free auditing framework provided by the certification
schemes and ensuring the transformation of the certification
requirements into practical audit documents, checklists and
guidelines via the scheme

b) enable a regional and technical multi-stakeholder dialogue

c) enable the scheme to set up a training and qualification program
for certification bodies, auditors and economic operators 

d) support the continuous management and improvement of the
certification set-up by the scheme

e) ensure the ability to run the scheme for global supply chains

f) establish and improve credibility via whistleblower tools,
companies and grievance mechanisms established and an integrity
program which is overseeing and monitoring auditor performance and
economic operators

We support the stakeholder process and are very grateful for the
opportunity to provide feedback on the planned project in this way.
we would be delighted if our feedback was taken into account.
Please do not hesitate to contact us if you have any questions.

With best regards
Peter Hawighorst