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
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
No GMO genetic engineering was performed on the crop.
No non-native plant species that is invasive
Use of Agriculture best practices, especially in
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
Dedicated energy crops do not include the following:
i. plant species that are genetically modified
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
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
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
A dedicated energy crop shall not replace existing forested land
or native habitat.