Sustainability Issues in Biomass Feedstock Production: A Policy Perspective - Engineering and Science of Biomass Feedstock Production and Provision - page 245

biofuels and biomass [ 105 ]. While fruitful in fostering dialogue, the GBEPs
progress toward building biofuels sustainability standards, and its ultimate effec-
tiveness, should not be exaggerated. Its framework to guide country-specifi c regula-
tion consists of indicators that are vague and noncommittal, which refl ects carry-over
of these more general failures to agree internationally on GHG or agricultural
sustainability metrics [ 106 ]. Its GHG accounting framework expressly refuses to
promote or endorse “one methodology or approach over another” with regard to
LCA “due to differences in national circumstances or legitimate differences of
opinion regarding what should be included in LCA” [ 107 ]. This begs the question
of how to resolve those differences when international trade occurs. While its social
indicators emphasize food security through “assessment” and “allocation” of land
resources, the GBEP has not explained how countries such as the United States,
with well-developed private property rights regimes, would “allocate” lands for
food and energy biomass production. Again, although the GBEP food security indi-
cator may be intended only to apply in underdeveloped countries with food insecu-
rity problems, arguably developed countries should be under the same requirement
as major actors in a fully globalized market economy for food commodities.
Although science is increasingly recognizing that the most effective solutions to
sustainability involve outcomes at the system level, the GBEP relies on actions
within and between jurisdictional boundaries that typically do not coincide with
ecological or social systems. Countries are only beginning to recognize that their
regulation and other policies should take into account the complex interactions that
occur environmentally within ecosystems or “sheds.” The US EPA's recent efforts
to reduce agricultural pollution loading in the Chesapeake Bay demonstrate aptly
the challenges that countries face in tackling agriculture's environmental problems
from a systems perspective. EPA has relied on modeling to establish maximum pol-
lution loading for each state, but it has proved no panacea, however, as plaintiffs are
now challenging in court the agency's use of modeled results that they argue are too
uncertain and thus are unlawfully arbitrary in application [ 108 ]. If the United States
lacks the scientifi c and legal infrastructure to design system-level solutions to sus-
tainability, the GBEP must consider how producers in less-developed countries
could comply with standards that seek system-level outcomes. The GBEP has great
potential to serve as a global research network to test sustainability principles across
ecoregions and to disseminate knowledge gained.
Even if scientifi c capabilities were in place, countries may not yet fundamentally
share a common “web of norms” to form the foundation for agreement on biofuels'
place within a sustainable system [ 109 ]. Although the GBEP involves the participa-
tion of over 45 countries and 24 international organizations and institutions consti-
tuting “the majority of bioenergy produced in the world,” [ 110 ] developing countries
have accused similar international processes as excluding their viewpoints [ 111 ].
While networks of association are important in coordinating globalized economies
[ 112 ], “the legitimacy of decision making becomes more strained as the sense of
community thins and the distance between those exercising authority and the public
grows” [ 113 ]. The GBEP must be very careful, therefore, to observe tenets of legiti-
macy in standard settings, such as transparency, notice and comment, and stake-
holder inclusion.