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

Abdul Razak Ayazi Alternate Permanent Representative of Afghanistan to ...
FSN Forum

We consider the Zero Draft on Biofuels and Food Security to be a science-based policy review of existing literature on biofuels and related issues, leading to some key recommendations of relevance to developing countries, especially those facing arable land limitation and severe food insecurity. However, there is room for improvement on the draft report and we look forward for the final version, incorporating the comments received from many individuals and institutions through electronic consultation.

Below are our comments chapter by chapter of the Zero draft report.


The introduction is fairly good and sets the stage for the study. However, it should inform the readers that renewable energy from all sources is a small portion of the  world’s total energy consumption (the IEA 2009 figure says 13.1%). The rest is all fossil fuel. In addition, the  global annual consumption of 120 billion liters of biofuels accounts for a miniscule of the overall fuel market for road transport. It is only 3 percent. This level of consumption is much below the optimistic prediction of 25% by 2050. We, therefore, suggest  the addition of a few short paragraphs on the composition of world’s renewable energy and the place of biofuels in total renewable energy.

The introduction should also underscore the fact that the biofuel market, especially ethanol, is grossly distorted by heavy subsidies, tax credits and high trade barriers. Without these incentives and protective measures, biofuel production will be uneconomical for producers, except in some countries like Brazil. It has been documented that the cost per barrel of biofuel in Brazil is about half of USA and one-third of EU.    

The introduction should also highlight two other important things. One, that  biofuels are not that green as originally thought, even the second generation biofuels. Biodiesel from soybeans and rapeseeds have a carbon print that is considered higher than the conventional diesel or gasoline. Similarly, the burning of forests to prepare land for the production of sugarcane, soya and palm oil as feedstock releases vast quantities of CO2 and often cancels the climate benefits associated with biofuels.  Two, biofuel is not a panacea for world’s energy crisis. In fact, the present euphoria for it may be distracting attention from the urgency of finding alternative renewable sources of energy. However, biofuel production could be the route to next technological breakthrough in diversifying the sources of energy such as from wood, grass, organic waste and solar energy.   

Chapter 1 ( Biofuel Policies)

There is no global or regional policy on the production and consumption of liquid biofuels for road transport. In fact, there is no global policy for fossil fuel either. But national policies exist in many developed and developing countries. However, none of the national policies are market driven. The policies have been put in place through legislation induced by environmental concerns and/or the desire to reduce reliance on imported fossil fuel. Some national policies have proved relatively successful and others not so successful.

Unquestionably, the chapter provides a concise and thoughtful overview of national policies on biofuels, especially by the major players (USA,  EU, China, Brazil and India).  Section 1.6 (country-based typologies) is very useful and may be worthwhile developing it further by making use of land data included in FAO’s publication ( SOLAW), especially Chapter 3 and Annex 4,  and  taking water availability as another key factor influencing the production of feedstock for first generation biofuels.

Given the diversity of policies pursued by developed and developing countries and the danger associated with their continuation, the draft report should have made an attempt to flag the idea of an international protocol for rationalizing the production, consumption and trade of biofuels.  Recommendation 2 of the draft report (i.e. the principle of prior, informed consent and full participation of all concerned in land investment deals) falls far short of ideas in support of a possible international protocol.  

Chapter 2 (Biofuels and the Technology Frontier)

This chapter adequately explains the technologies currently employed in the production of bioethanol and biodiesel and their efficiencies in terms of energy balances. However, it should have been more forceful by saying that technologies for first generation biofuels are evolving and hopefully will become more cost-effective and profitable, which, in turn, might have a positive influence on decisions by policy makers and farmers and processors of biofuels.

The Chapter also presents an fair assessment of second generation technologies for biofuels, though this subject remains somewhat speculative and it is hasty to draw any firm conclusions. Nevertheless, one could say with a fair degree of confidence that the prospects for second generation technologies in developing countries do not look promising over the foreseeable future.  

The prospects and limitations of jatropha and algae in the production of biofuels are also fairly assessed in the draft report and the three points highlighted in section 2.3.1 are indeed  pertinent.

Chapter 3 (Biofuel, Food Prices, Hunger and Poverty)

In tracing the precise effects of biofuels on food prices and of the latter on hunger and poverty is by no means a linear process and therefore the subject is open to question. However, the linkages between these variable cannot be denied. The main argument used in the literature is that the production of biofuel takes away grains from the global commodity markets, thereby forcing food prices to rise and encouraging farmers to clear tropical forests for new agricultural land. Therefore, we tend to go along with the statement on page 22 of the draft report which says “In truth, we do not know what percentage of reduction in consumption the food insecure experience when crops are diverted to biofuels and prices rise. Yet these very rough figures provide reason to believe the effects is substantial and could be extremely substantial”.

The experience of the last decade as presented in section 3.2 is undoubtedly valuable but it is largely based on  events in one major biofuel producer (USA). The inclusion of experience from other biofuel producers would have enhanced the quality of the chapter.

The influence of other factors as explained in section 3.3 is appropriate and convincing but putting the culprit on Chinese Stock Management may be somewhat premature. We find the contents of sections 3.4.2 , 3.4.3 and 3.5 to be useful, especially 3.5 which places the future demand and price effect of biofuels in proper perspective.

Chapter 4 (Biofuel and Land)

It is difficult to grasp the core essence of this chapter? Does it relate to land use in general or to some specific aspects of land use influenced by the increase in the production of biofuel feedstock, whether this be food crops or lignocellulosic material?

Generally speaking, we have no problem with the information assembled in the chapter.  What is not clear is in what way the analysis presented is linked to biofuels.

 In our judgment , the parts of land use relevant to biofuels are sections 4.2.2, 4.2.3 and 4.2.4. The rest of the chapter is marginally related to the subject matter under discussion.

There is a general consensus that biofuels, which feed vehicles, is taking away a lot of land from crops which feed human beings and animals. This situation is unsustainable and therefore must come to an end. In this connection, the OECD estimates that in the absence of new technology, North America and the EU would require between 30 to 70 % of their crop area if 10%  of their transport fuel were to be met from biofuel.

With good confidence one can say that a sharp increase in the production of biofuel feedstock, either from virgin land or from the intensification of existing crop area, is undermining many ecosystem service.

Chapter 5 (Social Implications of Biofuels)

The basic purpose of this chapter should be clarified. That said, the three points raised in the chapter (certification schemes for social compliance; gender issues in biofuels; and the multiple use of biomass to ensure energy security) are all important and need to be given serious consideration. And it is good to see that the three points are reflected in the brief section on recommendations. Yet, the three points should have been parts of the broader picture.

We support the importance of the four principles mentioned at the bottom of page 53.

Draft Policy Recommendations

Each of the 11 paragraphs in this section has a message. However, in some paragraphs it is not clear as to what is being recommended.  From our reading of the 3 pages, we conclude that:

  • The last bold sentences of the first six paragraphs can definitely be considered as recommendations;
  • Paragraph 10 related to alternative policy measures is a good one but it needs to be formulated in the language of a recommendation;
  • From the remaining four paragraphs (paragraphs 7, 8, 9 and 11), it is not clear what the recommendations are?

For ease of reading, it is advisable to number the recommendations.

Finally, we wish to suggest the inclusion of a small chapter devoted exclusively to the benefits and risks associated with biofuels. This should come before the recommendations.