Common Purpose and the University of Florida fully support the need for sound-science based environmental standards for energy crops ("closed loop biomass"), and we are actively working with environmental groups such as the Center for Resource Solutions (Green-e Accreditation) and the Florida Chapter of the Sierra Club to develop these Standards.

Three underlying principles that any Energy Crop must satisfy are:

  No GMO genetic engineering was performed on the crop.
  No non-native plant species that is invasive is allowed.
  Use of Agriculture best practices, especially in water use.

Proposed Environmental Standards for Energy Crops in Florida (drafted by the Florida Green-e Accreditation Group, Florida Sierra Club):

The following definitions apply to this paragraph:

i. Dedicated energy crops means plant species such as short rotation woody crops and perennial grasses.

ii. IFAS means the University of Florida Institute of Food and Agricultural Sciences.

iii. IFAS Assessment means the IFAS Assessment of Non- Native Plants in Florida’s Natural Areas.

iv. IFAS Evaluation means an evaluation prepared by one or more IFAS faculty members on plant species that are not currently in cultivation in Florida.

v. A naturalized species means a non-indigenous species introduced to Florida that is: 1) adapted to a climate, ecological site, or environment in the state; and 2) can perpetuate itself without fertilizer, pesticide or herbicide.

vi. A genetically modified organism means a species that is genetically engineered with techniques that alter molecular or cell biology of an organism by means that are not possible under natural conditions or processes. Genetic engineering includes recombinant DNA and RNA techniques, cell fusion, micro- and macro-encapsulation, gene deletion and doubling, introducing a foreign gene, and changing the positions of genes. Genetic engineering shall not include breeding, conjugation, fermentation, hybridization, in-vitro fertilization and tissue culture.

Dedicated energy crops do not include the following: i. plant species that are genetically modified organisms;

ii. plant species listed on the Florida Exotic Pest Plant Council’s list of invasive species;

iii. plant species that the IFAS Assessment concludes are in the categories “No,” “Avoid with Risk Benefit Analysis,” or “Avoid and Reassess in Two Years,” and finds that there are no management practices that can be used to prevent the invasiveness from causing a negative environmental impact;

iv. or a plant species that the IFAS Evaluation determines 1) can become naturalized, 2) is invasive, and 3) would cause a negative environmental impact that could not be prevented by management practices.

Each dedicated energy crop species must be approved by the Stakeholders to become an eligible fuel. An energy crop species shall not be approved until the results of the IFAS Assessment or IFAS Evaluation are submitted to the Stakeholders.

The IFAS Evaluation is initiated by the Stakeholders submitting a crop species to the Director of the IFAS Center for Aquatic and Invasive Plants for evaluation. The Director shall then identify one or more faculty members who can conduct the IFAS Evaluation. The Stakeholders shall then select the appropriate faculty member or faculty members to conduct the IFAS Evaluation. The IFAS Evaluation shall contain at least the following information:

i. The invasive characteristics of the species.

ii. If the species has invasive characteristics, whether there are management practices that can be used to avoid a negative environmental impact.

iii. If a species is not invasive or a negative environmental impact from its invasiveness can be avoided through management practices, then a description of the management practices that will ensure that the species does not have a negative environmental impact.

iv. If a species is not naturalized, the likelihood of the species becoming naturalized.

The IFAS Evaluation does not constitute a thorough evaluation of the species to be introduced. The IFAS Evaluation is only intended to indicate the likelihood that the species under review may or may not exhibit invasive characteristics based on what is currently known about the species.

An energy crop species approved by the Stakeholders that has not been reviewed by an IFAS Assessment must undergo such an assessment within two years and six months after being approved by the Stakeholders in order to remain an eligible fuel. The results of this IFAS Assessment shall be submitted to the Stakeholders. The Stakeholders may reevaluate whether the energy crop species is an eligible fuel based on the IFAS Assessment.

A dedicated energy crop shall not replace existing forested land or native habitat.