ISCC's statement on the recent "Biofuel Sustainability Performance Guidelines" of the NRDC
(Natural Resources Defense Council)
Cologne, August 5, 2014
In July 2014 NRDC published a report on “Biofuel Sustainability Performance Guidelines” which is intended to compare the quality of different certification systems for biofuels with respect to a considerable number of criteria. ISCC is convinced that this study does not serve its purpose since it does not meet basic professional quality standards; it contains numerous inconsistencies, uses unsubstantiated value judgments and contains basic factual errors.
Benchmarking complex sustainability certification systems is obviously a challenging task and ISCC welcomes efforts to create transparency for potential users of certification systems about their pros and cons. A number of state of the art benchmarking studies already exist which meet certain best practice principles. Unfortunately, the study commissioned by NRDC does not meet these standards.
ISCC was more than surprised to see in the just published NRDC report on “Biofuel Sustainability Performance Guidelines” that ISCC ends up with the lowest ranking of all certification systems reviewed. We believe this rating to be incorrect and we fear that it might create a negative view of ISCC thus damaging ISCC’s reputation.
ISCC has reviewed the NRDC report in detail and our assessment is that the report has factual errors, exhibits misunderstandings of ISCC, has not taken account of all relevant ISCC documents, has applied opinionated criteria that have not been applied to other systems and has suffered from the lack of due process in dealing with ISCC.
In mid-2013 ISCC was given the opportunity to see a draft of the document that was prepared for NRDC. ISCC commented to NRDC on the report. However, although ISCC has offered to discuss any contentious issues, there was no feedback either from NRDC or the authors of the study.
The result is a flawed evaluation of ISCC – possibly some other systems as well. We point out just a few examples, which highlight the lack of quality of the report:
- Two systems are included for comparative analysis in the NRDC report, the Forest Stewardship Council (FSC) and The Council on Sustainable Biomass Production (CSBP). Neither of these systems is actually a biofuel sustainability certification system and both are not recognized in any market for this purpose. Yet, they are included in the report and provided with a higher ranking than ISCC even though they do not provide any service of sustainability certification for biofuels.
- ISCC EU is the certification system that applies to the sale of biofuels in the EU market, not in the US. Therefore, the laws of the European Union govern key aspects of the operations of ISCC in that market, but in the report this is assessed as a negative. The ISCC PLUS system is the one that should have been evaluated in the report in terms of how ISCC would work in the US market. Clearly, US laws such as the US EPA RFS 2 program would guide the operations of ISCC PLUS in the US biofuels market.
- The interpretation of criteria has been applied inconsistently and to ISCC’s detriment. For example, the CSBP standard is evaluated as achieving full compliance with respect to transparency criteria. But its website www.csbp.org is non-functional, and therefore no transparency exists. In contrast, ISCC is assessed in the report as not fully meeting this same criterion and is penal-ized in the rating even though the ISCC website is a full disclosure website providing access to all documents.
- For some criteria, several certification systems have been evaluated as not fulfilling the indicator itself but have been approved because of the availability of so called equivalent alternatives. There is no disclosure in the report as to what kind of alternatives qualify for this inclusion. But, it seems impossible that while between 11 and 14 alternatives have been identified for each of the other systems evaluated, the report only identified four for ISCC. The authors of the report should have described and evaluated these alternatives in order to ensure the integrity of the report.
- There are basic factual errors in the report. It states that ISCC is closely associated with the German government’s BLE (Bundesanstalt für Landwirtschaft und Ernährung) agency; this is not true. ISCC is a fully independent not-for-profit organization that operates under an independent Board of Directors and reports to its members. There is no association between the German government and ISCC, yet the report casts negative comments on a relationship that does not exist.
- There has been an incomplete review of ISCC documents as only two ISCC system documents were stated as reference documents used by the authors in the preparation of the report on behalf of NRDC. For the evaluation of ISCC only three system documents have been taken into consideration. Important ISCC documents such as quality management, requirements on certification bodies, complaints, appeals and arbitration, etc. were ignored in the evaluation even though these documents are readily available on the ISCC website.
The process with which the report was conducted on behalf of NRDC contrasts sharply with that used by WWF Europe in the preparation of their benchmark study of sustainability certification systems. The WWF recognized the complexities of such systems and wanted to ensure that it used the most complete and up to date information about each certification system in order that its evaluation accurately reflected how each system operates. The WWF not only reviewed all documents but engaged in extensive discussions with certification systems being evaluated. In contrast, there have been no discussions between NRDC researchers and ISCC.
ISCC believes there is a need for and welcomes a thorough, fact-based comparison of the different biofuel sustainability certification systems. However, any report should be derived from a transparent process, just as it is required for certification schemes.
ISCC considers the NRDC work as very important, but this report is damaging to both NRDC’s and ISCC’s reputation. Therefore, we have asked NRDC to withdraw the report until appropriate changes have been made which correct many significant errors with regard to the evaluation and rating of ISCC. ISCC would be pleased to cooperate with NRDC in this regard.