ePURE represents the interests of European renewable ethanol producers to the European Institutions, industry stakeholders, the media, academia and the general public. Based in Brussels, ePURE represents 53 member companies throughout 17 member states, accounting for about 90% of the installed renewable ethanol production capacity in Europe.
Summary of our response
The European Renewable Ethanol Association (ePURE) welcomes the opportunity to participate in the consultation exercise to support the HLPE report “Biofuels and Food Security”. ePURE is extremely disappointed by the content of the draft report, believes that is not in compliance with what was requested to be carried out and is unnecessarily negatively biased against biofuels.
In October 2011 the UN Committee on World Food Security (CFS) recommended a “review of biofuels policies – where applicable and if necessary – according to balanced science-based assessments of the opportunities and challenges that they may represent for food security so that biofuels can be produced where it is socially, economically and environmentally feasible to do so” (emphasis added by ePURE).
To support this, the HLPE’s mission is to “conduct a science-based comparative literature analysis taking into consideration the work produced by the FAO and Global Bioenergy Partnership (GBEP) of the positive and negative effects of biofuels on food security” (underscoring by ePURE). We believe that that HLPE have failed to meet this standard in the current draft report.
In the report, the authors state that: “The central concern of this report is to analyze the implications for food security of global and national biofuels markets…through an evaluation both at the aggregate level of macro data and through field research carried out in different regions and localities”. The authors’ objectives are, therefore, completely inconsistent with the mandate of the HLPE. Within the report there is no science-based comparative literature analysis of the positive and negative effects of biofuels on food security, which is considered the mission of the HLPE. We therefore believe that the report is its current form is insufficient and in urgent need of revision.
Specifically, the HLPE fails to complete its mission in several respects:
In the following we provide some examples that support the criticisms that we bring to the report. This list is by no means exhaustive but serves to exemplify the incoherence, multiple factual errors, strong bias and lack of scientific rigor that the report suffers from.
The fact that this paper only looks at biofuels is quite alarmingly, considering that biofuels are only responsible for 3% of global cereals demand: meaning that the markets(s) for 97% of global cereals demand are simply ignored. This creates a narrow, incomplete view that, instead of adding value to the debate about food security, singles out biofuels for special attention. Debates about food security must be more holistic if real solutions to hunger and food security are to be found. There is no assessment about the relationship between agricultural trade flows and access to food or on the role of governments, and governance structures.
Within the report there seems to be a general confusion about the differences between food prices and commodity prices, the two are very separate issues and this is not sufficiently developed within the report.
The paper ignores the multi-product nature of biofuels production, promotes a zero-sum attitude to biofuels feedstocks as being either “food” or “fuel”, and fails to significantly factor in the mitigating impacts of co-products on prices of, for example, animal feed.
The analysis of the impacts of US biofuels policy on corn prices is not adequate or sophisticated enough and it does not explain why the removal of the VEETC (the main policy support for biofuels) in the US has not led to lower corn prices.
However, there are some elements of the report that we do agree with. In developing countries, bioenergy projects should provide immediate benefits to local smallholders and rural dwellers, therefore bioenergy use should be prioritised for local consumption in developing nations. CleanStar Mozambique is a local project that is harnessing the benefits of domestically produced ethanol, as a clean, renewable and environmentally friendly fuel, to provide access to energy and health benefits for rural people. More projects such as this need to be supported, while governance systems need to be improved in developing countries to prevent land grabs by foreign companies.
The report reads more like an opinion piece, criticising biofuels, instead of what it should be: a value-free expert opinion on the impact of biofuel production on soft commodities and food prices. The whole narrative of the report is skewed towards attacking biofuel, reflecting an underlying bias. There is not a single paragraph, or consideration given, that describes the real positive effects of biofuel on the feed/food sector.
The report lacks a sound methodology, or any transparent methodology for that matter, and uses unreliable data, in some instances from anti-biofuels interest groups, which has never been peer-reviewed or tested independently. Often the report makes claims that are not substantiated by any evidence. For instance, the report blames biofuels for land grabs in developing countries, but yet the report does not submit any evidence on the biofuel volumes traded between the main biofuel markets (Brazil, USA and the EU) and the countries where land grabs are proposed to have taken place.
The Introduction of the HLPE report states that "[f]ood security will be analyzed in light of the four components comprising the FAO definition, adopted by the HLPE, namely: access whose principal determinant is the ratio price of food/income, availability which is associated with the resources for food production . . . stability . . . and use” [emphases added by ePURE]. The report then proceeds to ignore these four criteria in their entirety. For example, the vulnerable community most often cited is "sub-Saharan Africa", yet there is no discussion of food prices and incomes in that region.
Regarding the mandate of the project, the project team that drafted this report apparently lost sight of what they were supposed to do. The report is neither science-based nor balanced, and is not a literature review. The report serves to only criticise biofuels and does not reflect in any possible way on whether biofuel can provide opportunities and/or the positive effects of biofuels on food security. This approach is out of step with the UN FAO’s own position.
As recently as May 2011 the UNFAO said that investment in biofuels could actually help to improve food security in rural economies by creating jobs and boosting incomes. Heiner Thofern, head of the FAO Bioenergy and Food Security Project, said that if "done properly and when appropriate, bio-energy development offers a chance to drive investment and jobs into areas that are literally starving for them." In 2011, the FAO released the study, “Making Integrated Food-Energy Systems work for People and Climate”, which stated that "investment in bioenergy could spark much-needed investment in agricultural and transport infrastructure in rural areas and, by creating jobs and boosting household incomes, could alleviate poverty and food security." It concludes inter-alia that “there is great potential for the co-production of food and fuel using existing methods and technologies.”
In the report the only reference that is made to the possible positive effects of biofuels on food security is that “they (biofuels) open up the possibility for new sources of income and employment, and provide alternative sources of energy for rural communities and for rural and urban food preparation”. While this is true, the authors completely ignore the biofuels production yields substantial volumes of valuable, protein-rich animal feed that goes into the food chain. In 2012 the UN FAO published a major report (over 500 pages long) titled “Biofuels Co-Products as Livestock Feed: Opportunities and Challenges”, which outlined the positive effects of biofuels co-products on food security, and this report is completely ignored by the HLPE.
The paper fundamentally ignores the multi-product nature of biofuels production, promotes a zero-sum attitude to biofuels feedstocks as being either “food” or “fuel”, and fails to significantly factor in the mitigating impacts of co-products on prices of, for example, animal feed.
The report offers no literature review or balanced investigation of the available science, but rather uses evidence, often not peer-reviewed, to support a pre-determined view that biofuels policies are driving up
food prices and causing problems in 3rd countries.
Bold statements such as “as a consequence (of biofuels mandates), land in many countries, which may have neither domestic targets/mandates nor large transport fuel demands, has also become the object of biofuels investments” are massive generalisations and are not supported by corroborating evidence, such as biofuels trade data or empirical evidence.
An example of the clearly anti-biofuels trend running though the report is in section 4.1.2 where the authors discuss the differences between photovoltaic technology and photosynthesis and conclude that biofuels will not 100% replace oil use, due to land and feedstock constraints. Firstly, this section is entirely irrelevant to “a review of the literature relating to food security and biofuels” and seems more like a political manifesto in support of electric vehicles. Secondly, most industry observers recognize that there is no silver bullet for replacing oil use in transport and that future measures will need to include a mix of 1G biofuels, 2G biofuels, 3G biofuels, along with energy efficiency measures (driving less), vehicle efficiency (better engines) measures, electrification of transport modes, and the introduction of hybrid vehicles.
We believe that the report naively over-exaggerates the role of biofuels in food prices and food security. For example, the report claims that biofuels policies are the predominant factor in food price rises since 2004 – but it does not offer evidence to qualify this assessment. A 2010 World Bank report “Placing the 2006/08 Commodity Price Boom into Perspective”, which dispelled the myth that biofuels had caused the commodity price spikes, has been completely ignored. Other key studies, which showed that biofuels had little effects of food prices, that were omitted include: Prof. Dr. Harald von Witzke (2011), “Impact of Bioenergy on food price is overestimated”, Hearing in the German Bundestag” and Joint Research Council, European Commission (2011), “Analysis of Agricultural Commodity Price Volatility”.
Expressions and rhetoric contained within this report unveil an underlying assumption of the authors: that the world does not currently produce enough food. For example, the paper makes the claim that food production needs to be increased, but does not detail why. This assumption is simply wrong, is not corroborated by evidence and, in fact, evidence from the UN itself contradicts it. The UN FAO has said that globally there is enough food produced to sustain 12 billion people. It is well understood, that global food production far exceeds our needs today; however hunger is still a global challenge but there are other ways to combat this problem. Singling out biofuels is taking the easy option and ignores the much harder global policy, and also lifestyle, choices.
A 2011 report by the UN FAO “Global Food Losses and Food Waste” revealed that the world wastes 33% of food produced for human consumption each year, enough to sustain billions of people. The scale of food waste worldwide is unacceptably high. One quarter of the 1.3 billion tonnes of food that is wasted is enough to feed all the hungry people in the world, according to the FA0. The study says that reducing losses in developing countries could have an "immediate and significant" impact on livelihoods and food security.
The HLPE report ignores the real problems in the food sector:
In the report it is stated (page 4) that “the relation between biofuels and food security is strongly influenced by the choice of feedstock and land-use”. In the EU, ethanol is produced from cereals and sugar. In 2012 EU bioethanol production used about 6,5 million tonnes (net) of cereals, representing some 0,24% of global grain supply and 2% of EU cereals supplies. 51% of EU cereals supplies goes towards feeding animals. In addition, around 3,5 million tonnes of out-of-quota sugar was used for the production of bioethanol in Europe. Out-of-quota sugar does, by definition, not compete with the food sector as EU prohibits it to be sold for food use. It is impossible that such low volumes could impact on structural commodity and/or food prices. In terms of land-use these crops require 1.4 mHa of land, less than 1% (0,76%) of EU agricultural land. That is far less than the 7 mHa of land than can no longer be used if the new common agricultural policy rules on set-aside become reality. It is also insignificant compared to all the land that is needed outside the EU to feed Europeans (38 mHa) which is the direct result of free trade agreements.
The HLPE report is incorrect regarding the amount of land used to grow biofuel feedstocks. Current global land use for biofuels is minimal, using about 3% of total global arable land area. There are currently massive amounts of unused, underproductive or marginal land available that could be used for biofuel production without compromising food production. A 2011 study by the University of Illinois found that there is an additional 320 – 702 million hectares of global land available for sustainable biofuels production. This is “an area that would produce 26% to 56% of the world’s current liquid fuel consumption.”
Some argue that if the land and crops used for biofuels production would not be used for biofuels then more people could be fed. This is unfortunately a misconception and a poor understanding of how the EU’s modern CAP functions. Farmers in the EU no longer produce for virtual markets; markets need to be real. If there is no market, then there is no production. Land will stay idle if no crops can be grown that can be sold for a profit. For example, replacing soy-imports by for example lupine, to increase the EU’s own protein production, is economically not feasible due to free trade arrangements. The only solution would be to subsidize growing lupine, but this would go counter to what the EU has abolished a number of years back.
Unsubstantiated claims and assumptions
Within the report there are also many examples of the use of ambiguous words such as “probably” and “could”. For example, on page 31-32 the authors speculate that “the growing Chinese demand for soybean imports would probably have created some pressure on crop prices even without biofuel growth”. “Probably” is not a scientific or factual terminology, and the inclusion of such is inherent to the lack of robust evidence that is presented within this report to support the claims of the authors, with a lot of these claims not scientifically referenced.
Fact check of the report
To summarise, we believe that the HLPE report: a) does not achieve its fundamental objective of undertaking a science-based literature review (of the negative and positive influences of biofuels on food security); b) lacks a transparent methodology and justification for the evidence that has been used; c) displays an inherent bias on behalf of the authors; d) displays a lack of scientific robustness, containing numerous unsubstantiated claims and assumptions; and e) contains a litany of factually incorrect statements. We, therefore, believe that the report is not can be improved substantially.
In order to improve on this first draft an independent review of the work must be carried out, in line with the HLPE’s own procedures. Such a peer-review must be conducted by external experts that are independent of the HLPE project team.
As a result, we believe that it is immature for the HLPE to recommend policy recommendations at this stage, based on the contents of the HLPE draft report.
Finally, we ask the HLPE project team to take note of a recent report by the Institute for European Environment Policy “EU Biofuels Use and Agricultural Commodity Prices: A Review of the Evidence Base (2012). The report says:
“The vulnerability of consumers across the world to food price increases differs markedly between countries and across households, depending inter alia on income levels, household composition, and on the household status as net consumers or producers of agricultural and food stuffs. We are not aware of studies that use multi-household models, which would produce a better understanding of the impacts of enhanced biofuel use on different population groups and allowing more solid estimates of the welfare impacts of biofuel policy. This gap should be closed in order to provide decision makers with a more complete evidence base feeding into the political review processes ongoing in 2012.”
 New tool for weighing pros and cons of bioenergy, UN FAO (2011).
 Making Integrated Food-Energy Systems work for People and Climate, UN FAO (2010).
 The Conundrum of Food Waste, New York Times (January 2013).
 Global Food: Waste Not, Want Not, Institution of Mechanical Engineers (2013).
 European Parliament Resolution (January 2012).
 All EU data from 24 January 2013 EU cereals balance.
 University of Illinois at Urbana−Champaign, Department of Civil and Environmental Engineering, Land Availability for Biofuel Production, 2011.
Related links and resources:
Biofuels and Food Security - A consultation by the HLPE to set the track of its study
Committee on World Food Security (CFS)
High Level Panel of Experts (HLPE)
The High Level Panel of Experts on Food Security and Nutrition (HLPE) Key Elements