41 Proposed Sustainability Threshold for Biofuel Projects In this section we

41 proposed sustainability threshold for biofuel

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4.1 Proposed Sustainability Threshold for Biofuel Projects In this section, we propose the adoption of a five-part legal threshold that could serve as the minimum requirements that must be met before biofuel projects are approved. They are: project eligibility screen, human rights impacts assessment, stakeholder identification and consultation, information disclosure system and project review mechanism. The threshold addresses the need for a pre-project analysis of any project to ascertain its nature and the manner in which it would be planned and executed. 1 Pre-project eligibility screen This test illustrates the need for a detailed description and analysis of a project proposal to ascertain the nature, objectives and likely impact of the project. Preliminary questions here would include whether the nature and scope of the proposed project raises any conflict with local priorities, the nature of technology involved in the proposal, the proposed location of the project including the criteria for site selection; and whether it could potentially affect the quality of the environment of the proposed location. To effectively answer these questions there is a need for a detailed environmental impact assessment early on in the project planning stages. There is a need for mandatory EIA for all projects at the planning stages. This would help shed light on the nature of the project and its likely social and environmental effects. The results of the pre-project analysis should be included in a comprehensive project description document (PDD) which would amongst other things detail the purpose and nature of the project; the likely short and long term environmental impact, and alternative measures to reduce the impact. The nature of information to be disclosed will include a detailed description of physical and technical characteristics of the proposed activity, including an estimate of the expected residues and emissions; the size, pace, reversibility, and scope of any proposed project or activity; the duration of the project and/or activity; the locality of areas that will be affected; a preliminary assessment of the likely economic, social, cultural, and environmental impact, including potential risks; a description of the measures envisaged to prevent and/or reduce the effects, including emissions in line with the precautionary principle; a description of personnel likely to be involved in the execution of the proposed project (including indigenous peoples, private sector staff, research institutions, government employees, and others); and procedures that the project may entail; information as to whether that the activity is subject to a national or transboundary environmental impact; a non-technical summary of the foregoing information and an outline of the main alternatives studied by the applicant; the main report and advice issued to the public authority at the time when the public
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235 concerned shall be informed of the proposed activity. 27 Information on projects and policies would also need to be completely disclosed.
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