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Re: HLPE consultation on the V0 draft of the Report: Biofuels and Food Security

Oxfam International ,
FSN Forum

Oxfam inputs on the draft 0 of the HLPE report on Biofuels and Food Security

First of all, we would like to thank the team of the HLPE for developing this draft. It includes very useful analysis and evidence. The draft 0 is a good start but the report should be further improved to inform CFS stakeholders on what is needed to ensure that biofuels and related policies are not undermining the progressive realization of the right to food.

•    The report recognize the central role of biofuels in provoking high and volatile prices as well as the critical role of mandates in increasing their impacts. However, the report fail to provide a clear recommendation on the need to eliminate mandates. This should be addressed to ensure that the recommendations are in line with the evidence included in the report.   
•    Looking beyond mandates into measures to constrain biofuels growth is key but it is complementary with the elimination of mandates.

Land and climate change related issues
•    Free, prior and informed consent is a critical principle to ensure local communities are protected against landgrabs. However, there is a need to further develop the analysis to include other key elements that have to be respected by investors (e.g. transparency, local communities’ fair compensation) as underlined by the CFS Guidelines on Tenure Governance. The report should clearly underlines that the full implementation of the Guidelines will provide a very strong contribution in addressing a number of land related issues raised by the report.
•    The report underlines that "as the evidence-base in terms of energy and GHG efficiency of first generation biofuels has narrowed, the impact of biofuels on food security has become an increasing concern".  This is a key point. The report should strengthen the analysis on this element. A section should be added. In fact, the fact that climate change was a core policy driver/underpinning rationale for biofuels support and policy and the fact that evidence doesn’t support it has changed the policy landscape.
•    As underlined by the 2012 HLPE report, climate change has massive impacts on food security and should therefore be a top priority. For this reason is important not only to call for the elimination of mandates but also for ILUC calculations in public policies. It would be very important to further develop the evidence base in the report on ILUC and biofuels.

Second and third generation biofuels
•    The analysis on advanced biofuels should be strengthened. The report should develop further the analyses for all options of advanced biofuels that are now being explored on the market. Further analysis can also help in further developing the recommendation #10.
•    The report encourages developing viable biofuels policies by focusing on biomass from waste products in order to use feedstocks that are non-competitive with food production.  However, the report should be further developed and propose analysis on potential options, on how waste can be defined and what sustainable criteria should be considered.

High and volatile food prices
•    The gender dimension should be tackled not only in relation to land but also to food price volatility.
•    The report should strengthen the evidence presented on the well-established linkages between biofuels and food price volatility. A wide range of report already provided in-depth analysis on this issue but is worth summarizing and updating it in the HLPE report. One specific element should be further explored: the link between biofuels policies and feedstocks. While biofuels demand put pressure on stock-to-use ratios for major feedstocks, some also argue that flexible biofuels production levels could also be used as adjusting factor to limit volatility (rather than the most vulnerable people). This should make the demand more elastic to price and have a stabilizing effect on prices.

Additional comments
•    The recommendations should be addressed to identified actors. It is not always clear if these need to be considered by member states, international organisations, other stakeholders. Relevant country-based typologies can be further developed, including identifying differentiated responsibilities and impacts, and more explicitly translated into specific recommendations.
•    The report encourages to promote certification schemes that are multistakeholder, fully participative and transparent (recommendation #6). It should be clearly underlined the crucial importance of including social criteria in certification scheme. As expressed in recommendation #7, it would be very useful if the HLPE report look on the idea of developing a strong common global Code of Conduct on biofuels to avoid proliferation of standards and risks that biofuels producers will choose the weakest ones, and reinforce the policy coherence of the CFS. The report touches here upon certain social issues like wages, employment or ecological issues like biodiversity, water use, but should provide further information about their relevance.
•    While the authors makes reference to the need for a more comprehensive bioenergy policy approach, what's clearly missing is a more fundamental recommendation for holistic energy policy approaches that argue for the reduction in the use of fuels as a whole. As rising energy demands are a key driver of biofuels production, a shift in focus towards reducing energy consumption is needed to ensure that pressure doesn't continue to build.

Specific comments
•    The report calls for using “prior and informed” consent (recommendation #2). The correct concept to be used should be “free, prior and informed consent” (FPIC) as recognized internationally in several normative documents.   
•    The report should be make clearer that CFS rai are not PRAI. There seem to be some confusion.
•    While it is true that the EU is starting to take a more prudent approach towards biofuels and this should be welcomed, the current draft is not entirely accurate in its presentation of changes in EU policy and overly optimistic about what the changes currently being envisaged would achieve. In fact, no changes have occurred yet; the European Commission (EC) has tabled a legislative proposal that will be amended and decided upon by the European Parliament and EU Member States. If adopted, the EC proposal would not limit blending of biofuels to 5%, it would only set an accounting limit on the share of “biofuels produced from cereal and other starch rich crops, sugars and oil crops” counting towards the 2020 10% target for renewable energy in transport; EU Member States would still be able to subsidise food-based biofuels above that limit and indeed have an incentive to do so because of another piece of legislation which the EC proposal fails to amend: the Fuel Quality Directive which sets a binding target of 6% reduction in the greenhouse gas intensity of transport fuels by 2020. To achieve a genuine “cap” or limitation in the blending of of first generation biofuels in the EU, the following additional changes in the current EU legislation are required: insert a reference to the limit in the sustainability criteria for biofuels defined in both the Renewable Energy Directive (RED) and the Fuel Quality Directive (FQD), so EU state aid guidelines will not allow subsidising biofuels above the limit. The EC’s proposed changes to EU biofuels policy also fail to restore the integrity of the policy from a climate change perspective: the EC proposes only a reporting obligation on emissions from ILUC rather than adding feedstock specific ILUC factors to the GHG accounting under the sustainability criteria of the RED and FQD.