Sustainability Issues in Biomass Feedstock Production: A Policy Perspective - Engineering and Science of Biomass Feedstock Production and Provision - page 242

rate and with amnesty for some rural producers who did not comply with the Forest
Code restriction prior to 2008. The World Bank contends that one side effect of the
RL and APPs is that if productive land must be otherwise “reserved,” agricultural
land use could move to more sensitive areas such as the Amazon [ 81 ]. Future dis-
cussion, therefore, could revolve around how to make reserves more economically
meaningful to producers (thus relieving the incentive to deforest elsewhere) and the
application of ZAE-CANA zoning restrictions. One way to do this would be through
certifi ed biomass production.
From a cross-compliance perspective, environmental licensing is required for
“high impact agricultural activities, including sugar cane ethanol facilities” [ 82 ].
Environmental licensing includes pre-project environmental review for compliance
with other environmental laws [ 83 , 84 ]. It remains unclear, however, whether
responsible authorities (states) require compliance beyond the biorefi nery to the
fi eld level. Pursuant to the “Green Protocol,” fi nancial institutions have agreed with
the federal environmental agency to condition lending on obtaining environmental
licensing [ 85 ].
The State of São Paulo has taken steps to phase out the burning of sugar cane
prior to harvest by 2021 under pressure to reduce air pollution and lifecycle GHG
emissions attributable to sugar cane ethanol [ 86 ]. In 2007, UNICA (the main
Brazilian sugar cane industry group) voluntarily agreed with the State of São Paulo
to reduce burning in all areas in anticipation of a 2013 deadline as well as no burn-
ing in new areas [ 87 ]. One signifi cant societal side effect of burning bans, however,
has been the elimination of hand labor in favor of mechanization. The UNICA
Agreement also involves other areas of improved sustainability. Its “technical direc-
tives” provide that sugar cane growers will observe a variety of sustainable prac-
tices, including (1) assessing areas that could contribute to environmental protection,
including biodiversity; (2) protecting water sources in rural areas; (3) implementing
soil conservation and watercourse protection plans; (4) properly disposing pesticide
containers and applicator training; and (5) adopting best practices to minimize air
pollution from industrial practices. In return, the State agrees to fund research,
install logistical infrastructure for exports, issue a “certifi cate of agro-environmental
conformity” as contained in the technical directives, and consider small holders in
designing anti-burning measures. The agreement establishes an executive commit-
tee of three technicians from the government and industry to establish criteria for
the certifi cate. “According to the State Environment Secretary, 145 out of 177 plants
in São Paulo have adhered to the Protocol” [ 88 ].
The 2007 National Plan on Climate Change recommends ways in which agricul-
tural and forestry practices can reduce GHG emissions, such as the adoption of no-
till techniques, strategies to deal with degraded pasture, integrated crop-livestock
operations, reduction in the use of nitrogen fertilizers, and organic “enrichment” of
cattle pastures to reduce nitrogen emissions [ 89 ]. The emphasis on improving pas-
ture in Brazil, particularly if it involves intensifi cation of cattle, has been activity
forwarded as one way to reduce ILUC penalties placed on biofuels. The drive
toward livestock intensifi cation may result in trading one environmental problem,
such as the ILUC, for another, because while biofuel sustainability standards may