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

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”. In line with this, the CFS requested the HLPE 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”.

The Final findings are to be presented to the CFS Plenary Session in October 2013.

The High Level Panel of Experts for Food Security and Nutrition (HLPE) now seeks input on the following V0 draft of its report to address this mandate. The current V0 draft has been elaborated by the Project Team, under guidance and oversight of the Steering Committee, based also on the feedback received through the scoping e-consultation.

The present e-consultation will be used by the HLPE Project Team to further elaborate the report, which will then be submitted to external expert review, before finalization by the Project Team under Steering Committee guidance and oversight.

The current draft is work-in-progress towards a comprehensive yet accessible and succinct presentation, highlighting priority topics and areas that are useful for action to the diverse range of stakeholders, which form the CFS.

To be useful in the next steps of the report write-up, the HLPE seeks feedback and input according to the following lines:

1.    Is the V0´s appreciation of the current policy conjuncture adequate, particularly its interpretation of the changing significance of mandates and targets?

2.    Does the V0´s interpretation of land constraints regarding “available” lands  – from an integrated food security and carbon emissions perspective – take into account all the relevant scientific evidence and arguments?

3.    The V0 provides a detailed and comprehensive discussion of the central role of biofuels for high and volatile food prices. Are there further discussions that need to be taken into account?

4.    The V0 endorses initiatives which give priority to broad bioenergy strategies for local use in energy poor regions of the world where the potential social gains are large from even small quantities of energy and the impact on land use competition small. Which are the most far-reaching examples of such policies or experiences in practice?
The V0 draft report presents a series of policy proposals, which are understood to follow on from the analysis developed in the different chapters. These proposals are still very preliminary and general in character. Do these proposals adequately reflect the analyses developed in the V0 draft? 

The Report ambitions to pay particular attention to the changed conjuncture with regard to mandates/targets and subsidies and to the need to define policies to control the development of biofuels markets. Contributions on this theme would be particularly welcomed.

The HLPE welcomes contributions and evidence to sharpen policy proposals, including international ones, in the area of implementing and ensuring effectively responsible land investments.

The HLPE is concerned above all to develop policy proposals, which can be used as practical guides for policy formulation, and welcomes contributions, which identify policies, and initiatives, which can flesh out the general orientations, presented in the policy proposals section.
We thank in advance all the contributors for being kind enough to spend time in reading and commenting on this early version of our report. Supplementary information, references and evidence-based examples would be very much welcomed in such a format that could be quickly managed by the team (for instance, if you suggest a reference, a book etc, please highlight a/the key point(s) in 5 to 10 lines).

Contributions are welcomed in English, French and Spanish. The V0 draft is available in English. We look forward to a rich and fruitful consultation.
The HLPE Project Team and Steering Committee

This discussion is now closed. Please contact for any further information.

Camilla Lagerkvist Tolke Swedish Board of Agriculture, Sweden
FSN Forum

Biofuels and food security is an important subject that needs to be discussed. The final report will be useful as foundation for this. That’s why it is important that the report is well balanced with equal treatment of the pros and the cons for biofuels and food security. This is why I have put a lot of effort in reading it and formulating our feedback and comments which follows here. I hope that they will be useful in the ongoing work to formulate the final report.

The final report would gain a lot of credibility by having a neutral tone. For the moment the whole draft is breathing that most of the authors are against biofuels and already had this point of view before starting to work with this matter. There are pros and cons for biofuels and the report would be better balanced and make a better foundation for discussion if these were neutrally presented and equally developed.

  1. The draft would also gain if it explained why we use biofuels. Using biofuels is a way to replace fossil fuels that have a heavy impact on our environment. All emissions of greenhouse gases contribute to climate change of which the effects reduce the conditions to grow food end feed (see point 4). And by reading about the impacts of fossil fuels we understand that the production of fossil fuels will be more difficult, use more energy and water and emit more pollution per gallon/litre as the years pass. There are also socio-economic effects from fossil fuels that are not often spoken of. This is very illustrative in the report by Pieprzyk et al. (Pieprzyk B., Kortlüke N., Rojas Hilje P., 2009, The impact of fossil fuels - greenhouse gas emissions, environmental consequences and socio-economic effects, November 2009, ERA - Energy Research Architecture).
  1. What we must do is to reduce the use of fuels as a whole, and find the amount of biofuels that the earth can handle for a start. To produce first generation of biofuels now and develop second and third in the coming years can have a positive outcome. Investing in agriculture for first generation biofuels give us the possibility to switch to food and feed production when we will need this, since our population is growing. But this requires laws and regulations and structures to follow up, about land, investments and development in the same way as these are needed for any investments, land use and social development. But if investors build infrastructure and let people develop we have biofuels now and food later. You can also ask yourself what’s the best of investing in oil production or in agriculture? Which of these would lead to development and better environment? It depends of how the investments are made.
  1. The report would also gain if the reasons for hunger and starvation were developed and how we could get food security. Now the reader could believe that biofuels causes hunger and starvation which is not the case. According to World Hunger Education Services (WHES) the causes of hunger have varied answers. Those are that 1) poverty is the principal cause of hunger which comes from lack of resources, an extremely unequal income distribution in the world and within specific countries, conflict, and hunger itself. 2) Harmful economic systems are the principal cause of poverty and hunger. Essentially control over resources and income is based on military, political and economic power that typically ends up in the hands of a minority, who live well, while those at the bottom barely survive, if they do. 3) Conflict as a cause of hunger and poverty. 4) Hunger is also a cause of poverty by causing poor health, low levels of energy, and even mental impairment, hunger can lead to even greater poverty by reducing people's ability to work and learn, thus leading to even greater hunger. 5) Climate change is increasingly viewed as a current and future cause of hunger and poverty. Increasing drought, flooding, and changing climatic patterns requiring a shift in crops and farming practices that may not be easily accomplished are three key issues. 
  1. One of the key messages in FAO’s “The State of Food and Agriculture 2012” is that Investing in agriculture is one of the most effective strategies for reducing poverty and hunger and promoting sustainability. Two other key messages are that Governments and donors have a special responsibility to help smallholders overcome barriers to savings and investment and Governments, international organizations, civil society and corporate investors must ensure that large-scale investments in agriculture are socially beneficial and environmentally sustainable.
  1. To reduce waste of food is also a matter to consider. Of the food produced globally only between 30 and 50 % end up on the table figuratively speaking. This is developed in the report Global food: waste not, want not (Inst. of Mechanical Engineers. 2013, London).
  1. In the draft there are a lot of statements of the effects from biofuels that’s valid for agriculture, trade or investments as a whole. This goes for the problems with gender, land grabbing, water, the rights and practices of traditional communities, monocultures, sensitive land, investments that benefit/don’t benefit the citizens, ILUC and so forth. These problems should be addressed with proper measures so that any form of investments, trade and agriculture is sustainable environmentally, economically and socially. These problems are not solved by banning biofuels, they still exist without biofuels. Biofuels have helped to put the light on these problems but should not be given the blame.
  1. What is also lacking in the draft are writings that show that the question is more complex than saying yes or no to biofuels as one product from one source to one purpose. We have different countries with different qualifications and different needs. There are different biofuels from different crops produced in different countries for different end uses. Biofuels is not one, it’s a complex mix of a lot.
  1. There should be a part that explains what happens with high and low world market prices (VMP). There are pros and cons with both. As late as 2005 FAO wrote that it was the low VMP on agricultural products that threatened food security for hundreds of millions of people. In reports from OECD, the World Bank and IMF they wrote that support in the rich countries are lowering the VMP which leads to low rural income in developing counties. When prices rose 2006-2008 many organizations changed now saying that it was the high prices that threatened food security. This has to do with that different groups of people are affected differently by high or low prices. Simplified we can say that consumers in a small open country are gaining with low VMP and that producers are loosing. With rising VMP consumers are loosing and producers gaining. There are even more parameters of this including that the net effect depends of the net consumption and local prices and VMP are not always coherent or co-changing. And there are short-lived and long-lived effects. Swinnen has written about this (Swinnen J., 2011, The Right Price of Food, LICOS Centre for Institutions and Economic Performance & Department of Economics, University of Leuven (KUL) & Centre for European Policy Studies, Brussels, January 2011).
  1. As a follower to the writings above: If the USA at this moment would forbid all maize to be used for ethanol, the world price of maize would fall and a lot of farmers for example in developing countries wouldn’t be able to sell their crops, loose income and have to leave or sell their land.
  1. In the draft it’s presented as if there are huge volumes of biofuels that have been developed since the oil crises of the 1970’s. This is not the case and this should be nuanced. Compared to the oil extraction, natural gas and electricity used for transport it was about 2.5 % 2010 including fuel from waste (Key World Energy Statistics, IEA 2012) or about 0.5 % 2011 compared to all energy consumption (BP Statistical Review of World Energy June 2012). And compared to agricultural land it’s 1-2 %. It’s the mandates in some countries, not all countries, which are ambitious.
  1. I also lack some facts about that the development of biofuels has had different reasons since they first were used in the nineteenth century. They have also had different reasons in different countries. First as fuel, driven out of competition by fossil oil, then for self-sufficiency in fuels, as disposal for agricultural products and the last decade to mitigate the greenhouse gas emissions. Europe introduced 1992 compulsory set-aside of agricultural land (about 10 %) which ended 2008, to hold back production. The European rapeseed farmers in the end of last century saw their profit diminish from the competition of soy as animal feed. For these reasons biofuels has in Europe been a solution! A modeling about the use of agricultural land shows that EU27 and Ukraine will probably get between 44 and 72 million of hectares of agricultural land free to produce biomass to bioenergy 2030 with the same self-support as today. This is mostly due to efficiency and effectiveness (Fischer, G. et al. 2010. Biofuel production potentials in Europe: Sustainable use of cultivated land and pastures, Part II: Land use scenarios. Biomass and Bioenergy vol. 34:2, pp 173-187).
  1. As for the high food prices it’s not new for economic theory that if you have a limited resource (arable land) the price will go up in the short term if supply diminishes or demand increases. If the changes are short-lived, the price will fall again. If the changes in supply and demand are here to stay the price will find a new state of equilibrium in the long term, higher or lower depending on what happens with supply and demand. There are a lot of things that influence the prices of agricultural products and each cause should be responsible for its part.
  1. With a higher price, farmers can get better paid and can invest. With laws and regulations that help the investments to be economically and socially fair this can be a way for regions to develop. Even with communal lands people might want to develop and that should be their decision.
  1. The credibility of the draft would also increase if there were sources for the statements made, if some arguments/statements were better founded/developed and some words/conceptions were explained. Here are some examples of those.
  • p. 6 What periods? What countries?
  • p. 21 “A wide variety of papers have found that biofuels have increased crop prices …”
  • p. 21 “Rising food prices lead directly to poverty impacts by causing the poor to spend more …”
  • p. 21 “As prices rise, some people will consume less, and that will be disproportionately the poor. For this reason, price increases also contribute to poorer nutrition.”
  • p. 21 “For these reasons, the role of biofuels in increasing food prices is directly relevant for discussions of poverty.”
  • p. 21 “For this reason, some models that predict relatively modest price rises due to biofuels, far from implying less of a problem from biofuels, actually predict a large effect on nutrition, and it is that effect that helps to hold down the rise in prices.”
  • p. 21 “As of 2010, biofuels used 5.9 % of all the energy contained in crops. If one third of those crops were not replaced, the food insecure experienced even one third of that reduction, the world’s food insecure on average would reduce their consumption by 9.5 %.”
  • p.23 “Although price increases are the method …”
  • p.23 “In line with … our analysis indicates that …”
  • p.23 “The simplest reason to believe that biofuels have driven large increases in grain prices is that it has made economic sense for biofuel producers to drive up grain prices dramatically.”
  • p.35 “In both case, … speculations do not consume more crops, they can only drive up prices by withholding more crops from the market. That means that for speculators to drive up the prices of stocks there must be an increase in stocks.” How does this work?
  • p. 35 3.4.4 Which models are better? And are they used for the other arguments?
  • p.35 3.4.4 “…and because the rise in biofuels has greatly increased the scope and rate of that rise in demand, it has played a predominant role in driving up prices.”
  • p.40 “In this report, … Yet, the incentive for farmers to do so is a higher price, and that same higher price encourages farmers to plow up new land and encourages the poor to eat less.”
  • p. 25 “Any effort … Why ethanol producers would not have bid …“ How do we know that they are ethanol producers that are bidding or not bidding?
  • poor
  • renewable fuels and biofuels
  • biofuels for transports and biofuels for electricity and heating
  1. There are some reasoning and arguments in the draft that don’t seem to fit in. These arguments are then used to say that biofuels are no good. To keep these reasoning and arguments in the report, they must be presented with a much bigger “if”, to show that these arguments are not valid unless all those very unlikely factors coincide. These reasoning and arguments are found on page 41.
  • “Today, if 100 % of world crop production were diverted to bioenergy, it would provide 13 % of world primary energy. …” Yes, to show that we can’t use all food and feed to biofuels, but we can use some production to produce bioenergy as long as it replaces fossil fuels, and that is what is interesting.
  • “To produce these outputs, … and devote 85 % of the water they withdraw from river and aquifers.” If I understand this right we already produce this so then we already devote 85 %. And we are not using 100% of the world’s biomass to bioenergy so this argument seems irrelevant. But it’s an argument to take better care of what is produced (less waste) and of water reservoirs for all purposes, we use water for oil production as well.
  • “The underlying limitation … even the most efficient plants tend to convert less than 0.5 % of solar energy into biomass.“ This happens all the time everywhere. I don’t see how this is a problem for biofuels? This blurs the discussion.
  • What this shows is that the world can’t use as much energy as we are because it’s too difficult to get it sustainable. That’s the real problem, not that we use biomass as energy.

Best regards

Camilla Tolke

Mr. Robert Vierhout European Renewable Ethanol Association (ePURE), Belgium

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:

  1. It does not conduct a science-based comparative literature analysis.
  2. The HLPE fails to provide any methodology used to perform the literature review, which is standard scientific practice. The report therefore cannot be qualified as a literature review, not even a balanced investigation of the available science. There is no justification given for the (types of) literature that has been included or omitted.
  3. The report serves to support a pre-determined view that a) the world is currently not producing enough food, and that b) biofuels are exacerbating hunger by driving up food prices and causing problems in developing countries. Readily available studies on positive effects of biofuels on food security are not presented, or considered, even when provided by the FAO itself. There is evidence to suggest that the outcomes of this report were already predetermined.
  4. In the report there are numerous unsubstantiated claims, not scientifically referenced, conjecturable and highly hypothetical. Some of the studies or material referred to are not scientifically peer-reviewed.
  5. The report uses data that is incorrect and omits key areas of research, such as research on the positive food price impacts of biofuels co-products. Sometimes irrelevant information is included.


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.

General comments

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."[1] In 2011, the FAO released the study, “Making Integrated Food-Energy Systems work for People and Climate”,[2] 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.

Anti-biofuels agenda?

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[3]. 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:

  • Chronic levels of food waste: In 2013 a report[4] by the Institution of  Mechanical Engineers revealed that 50% of global food production is wasted. Additionally, in 2012 the European Parliament revealed that 50% of food is wasted in Europe[5].
  • Lack of investment in agriculture, particularly in the areas of research and yield growth.
  • Lack of proper distribution of food.
  • Dramatically changing eating habits, with many people in Asia shifting towards meat diets that increase pressure on the agricultural system.

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.[6] 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.”[7]

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.

These include:

  1. Frequently in the report it is claimed that corn prices are linked to oil prices, while this is not sufficiently proven or corroborated.
  2. Page 3: “Biofuels cause poverty to the extent they force the poor to pay more for their food and less for other necessities and that turns on price increases” – where is the evidence for this? There is no supporting evidence provided that shows that biofuels cause poverty. It is an assumption.
  3. Page 6: “This has made EU policy, and biofuels more globally, highly sensitive to positions adopted within the scientific community and civil society.” What is the source for this causality? There is no source provided.
  4. Page 7: “From a feedstock perspective this involves a shift from cereals to oil crops where Europe is traditionally in deficit, and the promotion of oil crop expansion involving much direct land use change (DLUC).” Most of the rape seed for energy was grown on set aside land. Again there is no source to this statement.
  5. Page 18: “Table 2. GHG Emission reductions of select biofuels compared to gasoline and diesel excluding land use change impacts.” The EU law Directive 2009/28 included direct emission savings per biofuel pathway, moreover indicating the emission of fossil fuel (which is lacking in this table). Why are these data not used as reference? How is it possible to achieve an emission saving over 100%?
  6. On Page 19 (2.3.1): there is no literature reference included, despite several claims being made, and likewise on page 20, 2.4. there are also no literature references.
  7. Page 21: Chapter 3 starts with the statement that “A wide variety of papers have found that biofuels have increased crop prices and played a major role in triggering price increases but have disagreed about the magnitude and have less often directly addressed impacts on malnutrition.” Unfortunately the authors do not list this wide variety of papers; they also fail to acknowledge that not everyone shares that view. Again, if this were to be a balanced review of the evidence, reference would have been made to, for example, this paper: Policy Research Working Paper 5371, Placing the 2006/08 Commodity Price Boom into Perspective by John Baffes and Tassos Haniotis, The World Bank, Development Prospects Group, July 2010. This section completely disregards the distinction between commodity prices and food prices.
  8. Page 21: “The second section evaluates the dominant role of biofuels in the recent (we need to assume that this is 2012-ePURE) agricultural commodity price increases.” In this second section there is absolutely no reference made to the extensive research done by the US Environmental Protection Agency, who ran multiple scenarios to measure the effect of the RFS waiver on corn prices. It was found that the corn price effects of a waiver of the RFS mandate would be so dramatically low that agreeing to a waiver would be mere politics of symbolism. The fact that the word “dominant” is already used before the evaluation has been completed, or the outcome known, highlights that this report contains an inherent bias and that outcomes of analysis are already pre-determined and “fait accompli”.
  9. Page 22 last §: “In truth, we do not know what percentage of reductions 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 effect is substantial and could be extremely substantial.” Such a statement admits and displays to the complete lack of robustness of this report.
  10. Page 23 1st §: “We can therefore estimate that biofuels probably have had a meaningful effect on hunger and have the capacity to have much larger consequences if biofuel production continues to rise.”).  The words “estimate”, “probably” and “if” render this sentence unreliable. There is again no supporting evidence provided to support the statement.
  11. Page 23: “In the first place, with the rise of oil prices, it has been economically feasible for ethanol manufacturers to bid up the price of maize”. Why would an ethanol manufacturer do this? It is totally out of step with reality. The author clearly does not realise that higher feedstock prices mean higher production costs for ethanol producer, something which producers clearly do not want.
  12. Page 23: “The simplest reason to believe that biofuels have driven large increases in grain prices is that it has made economic sense for biofuel producers to drive up grain prices dramatically”. This is a value-assumption and a decision not arrived to by facts. For instance, this is not true considering that ethanol producers are, as much as any other sector, negatively affected by higher prices, with many examples of production facilities mothballing during times of high commodity prices. Historical evidence shows that during times of high commodity prices ethanol production slackens. This is not considered by the report.
  13. Page 24: Ethanol prices are not set by petrol prices. In the EU, the price of the ethanol is determined by the low-cost producers (either Brazilian producers or US producers). But what happens in the EU ethanol industry seems to be irrelevant for commodity prices because EU ethanol production is not mentioned at all in chapter 3. We then can only conclude that EU production has no adverse impacts on food prices.
  14. Page 25: “Any effort to explain why ethanol would have an effect on crop prices other than the doubling and tripling which we have identified (sic), has to start by offering a cogent explanation of why ethanol producers would not have bid up the price of ethanol (sic) near to these amounts as oil prices rose.” So first, it is assumed/claimed (and certainly not proven) that ethanol manufacturers drive up the corn price deliberately and then it needs to be proven by others that this has not happened. This is a bizarre way of reasoning: there is an accusation without proof and then the accused needs to submit the proof that the accusation is not correct. It seems that it has escaped the authors that several US ethanol producers went bust or had to stop producing because of high corn prices.
  15. Page 25: “The price increase implies that supply has not been keeping up with demand, which has allowed farmers to charge prices above the costs of production”. Yes, of course farmers will charge higher prices about the cost of production, it is called profit and it is the basis of the agricultural economy. Failure do to so would mean increased poverty and debt for farmers. One of the major problems in the developing world is that rural farmers have subsistence existences and do not get enough farm income. This statement typifies the ignorance contained within this report of the role of farmers as biofuels feedstock and food producers. Farmers produce for markets in order to sustain their lively hood.
  16. Page 32: “By comparison, the increase in biofuel production since 2004 has commandeered roughly 22.7 million hectares of additional, similarly high yielding lands.” We can only assume that this number has nothing to do with Europe. After all, many years rape seed production for biodiesel was grown on set-aside (idle) land and according to the FAO the EU yearly takes 0.5 mha of arable land out of production. In 2012 EU ethanol production used a maximum of 1,4 mHa of agricultural land, representing 0,76% of EU agricultural land, equivalent to the size of Northern Ireland.

Fact check of the report

  1. Page 1 (and throughout): “CSOs increasing role in policy (re)formulation is particularly evident in the decision to reduce the participation of first generation biofuels from ten to five per cent in the EU renewable fuels mandate.”…………..” We consider (sic) also analyze recent major changes which have occurred with regard to targets and mandates focusing particularly on the EU Directive which limits biofuels blending to half the original target and effectively establishes existing levels as a ceiling for first generation biofuels”. Throughout the report there is a misrepresentation of EU biofuels policy, portraying the 5% cap on crop-based biofuels as agreed EU policy. The 5% cap is part of a proposal for a draft law, it is not decided or agreed policy.
  2. Page 2: “Second generation biofuels use non-edible crops or the non-edible parts of food crops which require the use of lignocellulose technology”. HVO or BTL do not involved lignocellulose technology but are considered 2G biofuels.
  3. Page 6: “The principal driver in the EU was the fulfillment of commitments to the Kyoto targets (European Directive, 2003).” This is not correct. The 2003 Directive was an energy Directive not an environmental one. There were stipulated at least 3 objectives: a) diversification of energy supply, b) new outlets for the agricultural sector, c) decarbonising transport.
  4. Page 6:  “In the EU, a biofuels policy had to give priority to biodiesel...” This is not written in the EU Renewable Energy Directive, there is no such stipulation.
  5. Page 7: The EU has no renewable fuels directive. There is a renewable energy directive, and that does not mandate any use of biofuels; the entire 10% obligation could theoretically come from electric vehicles, biogas or any other renewable sources that displace fossil fuel in the transport sector.
  6. Page 7: “From a feedstock perspective this involves a shift from cereals to oil crops where Europe is traditionally in deficit, and the promotion of oil crop expansion involving much direct land use change (DLUC).” Most of the rape seed for energy was grown on set aside land. Again there is no source to this statement.
  7. Page 7: “the EU becomes structurally dependent on imports, either of biofuels, or feedstock, to meet its targets. This is true for ethanol imported first from Brazil and later from the US,” What is the source for this? The EU has both enough ethanol and biodiesel production and is not dependent on imports. For both biofuels, the EU has sufficient production capacity in place to supply the market: ethanol has currently 9 billion liters capacity for a market that is not even 5 billion now while there is 20 million tonnes of installed production capacity of biodiesel for a market that is just over 8 million tonnes. If imports from Brazil and the USA take place then it has more to do with the economics of trade (arbitrage yes or no).
  8. Page 7: “By 2020, the EU would be importing annually some 15.9 billion liters equivalent (Bowyer, 2010, German & Schoneveld, 2011). The EU biofuels policy, therefore, implies also the creation of an increasingly global market and the involvement of developing country agricultures”. The text does not specify if this is biodiesel and/or ethanol. In any case, for ethanol hardly any 3rd countries are able to compete with the prices of Brazil and/or US ethanol, even they had to pay no imports duties. Ethanol is a product like anything else and traders will always attempt to purchase at the cheapest possible price. Due to higher production costs many 3Rd countries cannot produce ethanol at a competitive enough price to rival Brazil and/or the US.
  9. Page 7: Figure 1. Net trade streams of wood pellets, biodiesel, and ethanol, 2011. The trade streams are incorrect: a) there were no bioethanol (that is, ethanol for fuel use) imports from Russia, Ukraine, Africa or Pakistan. Most of the imports came from the USA and a small volume from Brazil (Eurostat data).
  10. Page 7: “a 5.75% mandatory target fixed for 2010.” This was a voluntary target, not mandatory target. Directive 2009/28 for the first time introduced a mandatory target of 10% renewable energy by 2020.
  11. Page 16: “While biofuels could technically make significant contributions to the global energy supply, their market potential is likely to be more limited due to the amount of feedstocks that can be economically produced and harvested as well as their costs relative to those of liquid fossil fuels (Carriquiry, Du, and Timilsina 2011).” The authors are selective in their choice of literature. Both Bloomberg and WWF published reports demonstrating that it is possible to replace around half of global gasoline consumption by 2030 through sustainable biofuels: Bloomberg New Energy Finance (2012), “Moving towards a next generation ethanol economy”. Furthermore, a report by WWF (2011), “Energy vision – 100% renewable energy by 2050” states that biofuels will meet 50% of global transport fuel by 2050. Additionally, a report by the Öko-Institut (2011) “The Vision Scenario for the European Union” said that biofuels could meet 80% of EU fuel needs by 2050. In 2011 the European Commission’s Expert Group on Future Transport Fuels also published a report which claimed that biofuels in particular have the potential to replace Europe’s addiction to fossil fuel energy and make transport sustainable by 2050.
  12. Page 17: Figure 2. Biofuel production cost ($/Gj) from various feedstocks. These figures are not correct because they do not factor in co-products. If indeed the production costs are as depicted in the figure then we would see investments in sugarcane or sugar beet processing plants and not, as is the case in reality, investment in cereal processing plants. This is because production costs also depends on co-product revenues. The figure is suggesting a reality that is simply not there. The source document for Fig 2 on P17 is not listed in the Reference List. Same for Table 1, WWI 2007.  Table 2 makes no attempt to describe the GHG saving of the biofuels that are actually used, and ignores the requirement for minimum thresholds in both US and EU legislation (EU threshold 60% GHG saving from 2018). Such savings and thresholds have to be met after accounting for any direct land use change effects.
  13. Page 18: “The estimates are also highly variable and sensitive to the assumptions used in the LCA. A particularly important assumption is the treatment of land use and land use change including both direct and indirect (Searchinger et al., 2008).” Indeed in LCA, as well as econometric modeling, the assumptions made are to a large extent designing the output. The quoted work on ILUC was highly criticized by many scientists and over time it has become clear that the ‘calculated’ ILUC related emissions were heavily over-estimated. To comply with the intention to have a balanced report all of the research on biofuel LCAs and models to estimate ILUC emissions should be reviewed. That one of this report’s authors should reference their own work on ILUC, considering the contested nature of such, considerably undermines the credibility and impartiality of this report.

Final Remarks

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.”

IEEP (2012).

[1] New tool for weighing pros and cons of bioenergy, UN FAO (2011).

[2] Making Integrated Food-Energy Systems work for People and Climate, UN FAO (2010).

[3] The Conundrum of Food Waste, New York Times (January 2013).

[4] Global Food: Waste Not, Want Not, Institution of Mechanical Engineers (2013).

[5] European Parliament Resolution (January 2012).

[6] All EU data from 24 January 2013 EU cereals balance.

[7] University of Illinois at Urbana−Champaign, Department of Civil and Environmental Engineering, Land Availability for Biofuel Production, 2011.

FEDIOL , Belgium
FSN Forum

FEDIOL is the European Association representing oilseed crushers and vegetable oil refiners’ associations in 16 European countries, who produce vegetable oils and protein meals for food, feed, energy and non-energy technical uses. As an integral part of food, feed and biofuel chains, FEDIOL members provide about 20.000 jobs in Europe, often in rural areas, and contribute with 24 bln euro turnover to value creation and wealth in Europe.

We appreciate the opportunity of providing comments to the draft 01 version of the report on biofuels and food security.

The appreciation of the current mandate situation in Europe is misleading, because a recent proposal for capping the biofuel mandate at 5 % is taken for granted. In reality, the European Commission has submitted a proposal in October last year, which requires both the Parliament and the Council to come to an agreement on a whole set of changes to the biofuels policy that have been proposed.

Instead of providing a detailed and comprehensive discussion of the role of biofuels for high and volatile food prices based on existing literature, is seems to base its conclusion on rather one-sided evidence according to which biofuels have not only a central, but also a dominant the role. The fact that there are also numerous other scientists[1] who consider biofuels not to be the primary impact on commodity prices, does not appear in the report and does not lead to a contradictory debate.

More generally, the evidence collected throughout the report shows on a number of items considerable variability, leaving a high degree of uncertainty of the impact or consequence considered. Despite this uncertainty, the report gives the false idea that it can reach clear conclusions. For example, the report recognises on the one hand that “we do not know what percentage of reductions in consumption the food insecure experience when crops are diverted to biofuels”

(p.22). Yet, faced with such uncertainty, the report nonetheless reaches the conclusion that “these very rough figures provide reason to believe the effect is substantial and could be even extremely substantial.”

The report should give consideration to the positive contribution of biofuels production to the food chain, in terms of production of co-products, of investments in agriculture and in research. In certain regions, like Europe, which suffer from protein deficit for livestock production, biofuels production contributes to reducing this protein deficit and supports food production. With every tonne of rapeseed biofuel produced, 1,5 tonnes of meals supply the feed market and consequently the food market. The report does not expand on the positive effects of enhanced investments, increased production and of the regained research effort that has taken place following the biofuels development.

In this context, the report seems to ignore and even to contradict past FAO assessments. When in 2005 FAO said: „The long-term downward trend in agricultural commodity prices threatens the food security of hundreds of millions of people in some of the world‘s poorest developing countries“, it was precisely concerned of the lack of investment in agriculture, the insufficient positive signals given to farmers for enhancing production.

Furthermore, the FAO BEFS (Bioenergy and Food Security) analysis of bioenergy policies also recognises the three distinct advantages of biofuels, i.e. positively affecting agricultural and rural incomes, poverty reduction and economic growth through creation of new markets, reducing energy dependency, and enhancing food security. The BEFS analysis also concludes that general conclusions cannot be made as to the impact of biofuels on food prices, economic growth, energy security, deforestation, land use and climate change[2].

We consider problematic to make use of case-study evidence, as mentioned in the policy recommendations, to support an overall judgement of some consequences attributed to biofuels production, which appear to us more specific to certain countries or situations and then also even to draw conclusions and policy recommendations.

As it stands, the report appears as essentially made fit for the purpose of demonstrating that biofuels, in any case, are detrimental to food production and that mandates should be dismantled. We hope the report to offer a more balanced vision on the co-existence of biofuels and food production, without making a partial use of existing scientific evidence, and to remain consistent with the overall FAO policy approach.

[1] Prof. Dr. Dr. h. c. H. von Witzke - B Humboldt-University Berlin; Prof. dr. André Faaij – Utrecht University; Prof. Dr. Dr. h.c. P. Michael Schmitz - Justus-Liebig-Universität Gießen; Prof. Dr. sc. agr. Dr. h.c. Jürgen Zeddies - Hohenheim University...

[2] Bioenergy and Food Security: BEFS Analytical Framework’, FAO, Rome, 2010. 

Climate Change, Energy and Tenure team FAO, Italy
FSN Forum

Dear HLPE Secretariat

Please find attached comments from the Climate Change, Energy and Tenure team on V0 of the HLPE report on Biofuels and Food Security.

We have divided our submission in two parts.  The first section includes overall comments on the document and structure and the second part includes working level detailed comments on each section.

Generally there seems to be lack of cohesion across the document with the recommendation section presenting more balanced views and the rest of the document being written in a more negative and less substantiated fashion. We strongly suggest structural and technical revisions of this document.

Xiangjun Yao
Director, NRC

National Reference Center on Biomass (CENBIO/USP) , Brazil
FSN Forum

Dear sirs

Please find enclosed the document

Preliminary Comments from CENBIO (The National Reference Center on Biomass – University of Sao Paulo) on FAO HLPE Consultation Paper on Biofuels and Food Security

This document was prepared by CENBIO under the coordination of prof Jose Goldemberg (Zayed Award 2013) with comments from a group of experts on bioenergy

We hope comments and suggestions presented here will help to improve the FAO HLPE Consultation Paper

Please feel free to send us any comments and/or questions

Sincerely yours

Profa Suani Coelho, PhD
University of Sao Paulo - USP
CENBIO - The National Reference Center on Biomass - USP
Sao Paulo - Brazil

Alois Leidwein Austrian Agency for Health and Food Safety, Austria
Alois Leidwein

Dear colleagues,

I am sorry to say, but the VO draft paper on Biofuels and Food security is unbalanced.

The collection of data is commendable, but Summary, recommendations and chapter 3.1 look to me like an NGO paper that only takes into account one side of the coin.

It is a matter of fact, that 70% of the poor live in rural areas. most of them work in agriculture (IFAD Rural poverty report 2011). For them higher farm prices is the only way out of poverty and hunger.

Higher prices for agricultural products are the only way to boost production to the level we need for the next decades. otherwise farmes will not  have the money to invest.

Rising demand for food alone will not lead to prices which enable small and medium farms to invest or buy inputs

Demand for biofuels may enhance that rise of prices: for farmes (70% of the poor) that may be positive !!)

In a short or medium term higher commodity prices, even caused by biofuels, will chatch the farm gate in nearly any state.

It is clear that higher agricultural prices may cause problems for the urban poor. But it would make sense to evaluate the economic effects cuased by a farm population with slightly more money to spendand invest dfor the whole economy

The VO report only describes possible negative effects and ignores the possible positive economic outcome.

I kow the the problem: most models only take into account production and prices and don't go so far.

more comments:

1.            prices for oil or diesel will increase dramatically in a medium term. farmers will need alternatives. I do not see electric powered combines and tractors in rural regions (developed or developing) in the next 2 decades. You should discuss that problem as well

2.            landgrabbing is no phenomen of developing countries and caused only by biofuel production. even in industrialized countries like Germany and Austria investors, the church, "even NGOs"  startet to buy agricultural land where they can get, since the eceonomic crisis startet (fear of inflation). land was bought and rented by many state funds for food security reasons too. as land laws are a pure national compentence I think capacity building for politicians and farmers' associations is an option. 

3.            ILUC: Changing from intensive production to organic agriculture has the same effects on land change as biofuel production. In organic production the total output decreases by 30%. But inputs perunit produced stay at the same level as in concventional production. but you need 30% more land for the same output.

4.            please do not only cite agricultural and agro-industrial lobbies as advocates for biofuels  please tell which lobbies fight against biofuels too: you may cite

  • the oil industry
  • multinational food companies (like Nestle): they need low commodity prices for higher profit margins and
  • many NGOs which are not interested in change

I suggest to rework the study taking into account that  rural poor may be winners of a biofuel boom too. Please characterize the real loosers (urban poor and landless - but only for regions where the problem is a real problem) and some multnationals. please dicuss as well the role of farm workers

I do not want to read an FAO "Expert" paper that sounds like the press bulletin of Nestle, Oxfam or the catholik church

Best whishes for the further work.

This comment is written in my personal capacity. the comment s no official position of the Agency.

Dr.Dr. Alois Leidwein
Bereichsleiter/Head of Department
AGES - Österreichische Agentur für Gesundheit und Ernährungssicherheit GmbH
Wissenstransfer, Angewandte Forschung, AGES Akademie - WIF
AGES - Austrian Agency for Health and Food Safety
Research Coordination, Knowledge Transfer, AGES Academy

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.

Elisa Calcaterra EPFL - Energy Center, Switzerland
FSN Forum

Dear Sir/Madam,

Please find below a few comments to Vo of the report.

1.    Page 21: relation to poverty.

I concur with your distinction on impacts on poverty and hunger and I understand that the paragraph focuses on prices. I would suggest that it may useful to also mention (here or somewhere else) that impacts on access to food and directly on poverty (not necessarily by increase in prices) should not be underestimated.  This is often the case when biofuel developments cut off local communities/individuals from the resources they need to secure enough food (and other livelihood items) for themselves (it could be water, land for pasture etc.). In this sense, developments can have a direct impact on poverty, including by reducing access to food without necessarily impacting food prices as such. This is very relevant for those communities who rely heavily on growing their own food rather than buying food.

2.    Page 51: Certification schemes

a.    Part of the reason why the EC does not include social criteria requirements is to avoid a clash with WTO trade rules. This has been investigated in several research papers and briefs. One example is the research of Emily Lydgate, “Biofuels, Sustainability and Trade-related Regulatory Chill, Journal of international Economics, vol 1-24, 2012”.

b.    Although I agree with your statement on the inability of most schemes to look at social issues, I think it’s important to emphasize the work done by the Roundtable on Sustainable Biofuels to address the issue of local food security, which include screening based on FAO maps and requirements for food security impact assessment and mitigation measures. The RSB also comprehensively addresses land rights (principle 12), water rights (principle 9), and to some extent rural and social development (Principle 5) and labor and human rights (principle 4).

EPFL has also developed a methodology for low indirect impacts biofuels, which aims at promoting biofuels with low indirect impact risks. This was done in cooperation with WWF and a consultancy, ECofys. This work is available for any voluntary scheme to use as we believe that trying to discuss biofuels without more attention to their indirect impacts (including on food security), misses a crucial point and mistakenly focuses on direct impacts as if direct impacts should be the main and primary object of discussion.

Thank you for the opportunity to comment,

Best regards,

Elisa Calcaterra
EPFL- Energy Center
Château de Bassenges
Station 5
CH 1015 Lausanne

Partners for Euro-African Green Energy (PANGEA) , Belgium
FSN Forum
  1. Is the V0´s appreciation of the current policy conjuncture adequate, particularly its interpretation of the changing significance of mandates and targets?

On P.14 it is not precise what is written about the EU:  the EC issued a draft directive proposal that still needs to be discussed in the European Parliament and by the 27 EU member states before being approved, a process which will take up to two years and may end up with very different legislation that what is proposed.

There is no direct link between EU policy and African biofuels considering the very low quantity of African biofuels imported by EU. Imports have only ever equated to a few million litres or less per year, not on a consistent basis nor consistently be the same countries let alone the same projects.

Focus on Africa: The draft’s review of African biofuels policies is very short and does not reflect the complexity or reality of the situation at the moment. Some countries have already implemented policies, some are just beginning to define guidelines, while other countries, though the potential for biofuels production may be considerable, have not addressed the issue at all. PANGEA has compiled a database of all currently available biofuel policies in sub-Saharan Africa and understand that the picture related to African biofuels policies is more complex than what was included in just a few paragraphs in your V0 report. Additionally, the treat is “Everything but Arms,” not “All but Arms” as written on P.13.

  1. Does the V0´s interpretation of land constraints regarding “available” lands  – from an integrated food security and carbon emissions perspective – take into account all the relevant scientific evidence and arguments?

The land grabbing debate has become a contentious matter, and its effects will remain at the forefront of the debate unless a determined effort is made to eliminate this prevalent problem at its root.

Land in Africa is of particular interest to foreign investors for many reasons. Arable land is often in greater abundance than in their home countries, typically relatively cheap and with climates ideal for growing food and fuel crops. Consequently, there is a rush to acquire African land to secure food for high population countries where access to land is limited; for the extractive and cotton industries; and on which to grow biofuels.

The apparent ease with which investors are able to obtain land is alarming, and must be addressed. It would be prudent to consider how foreign investors can acquire vast tracts of land rather than seek to blame specific industries for this phenomenon. A closer investigation of African land tenure systems points to obvious weaknesses. These include a shortage of secure land rights; lack of functional and consistent institutional frameworks; the failure of stakeholders to remain transparent throughout land transactions; insufficient community consultation and a deficiency in application of rules regarding environmental and social impact assessments. These weaknesses render it possible for foreign investors to acquire the land they desire without taking responsibility for the consequences on local populations.

The root of the problem must be dealt with: land tenure systems must be strengthened and properly implemented. This inevitably involves greater coordination and cost between the various stakeholders.

Governments must carry out comprehensive land use planning. Land rights could be strengthened through registration schemes while improvements in monitoring and enforcement of laws as well as investment requirements would provide a consistent structure to deals. Furthermore, increased effort to ensure transparency throughout deals enables public scrutiny.

Investors have a responsibility to understand local tenure systems and to inform themselves of and avoid potential weaknesses. The performance of impact assessments is paramount and should be prioritised. Investors must sign up to certification schemes to ensure sustainability enabling commitment to contribute towards development. There is an onus on civil society to work with local groups to educate and support them and their claims to land while ensuring that investment moves forward to benefit the community.

Should interested stakeholders work together improving land tenure systems, then incidences of land grabbing can be reduced.

In November 2011, PANGEA prepared an informative report focussed on the contentious issue of landgrabbing. The aim of the report was to identify the true basis for landgrabbing and further to illustrate, through the provision of examples, that it is not a solely a biofuels problem as recent publications might suggest. In reality, biofuels play a relatively small role in the occurrence of land grabs.

The study investigated the current situation in three Sub-Saharan African countries and discovered that the majority of land grabs are to a large extent, the result of an inadequate land tenure system and weaknesses in the public law and institutional framework of the countries. It is inaccurate to blame biofuels for land problems in sub-Saharan Africa, the problem is more complex than that and it is linked to lack of secure land rights, lack of a functional and consistent institutional framework, lack of transparency in land deals and lack of consistent community consultation.

The study was released at the same time as the International Land Coalition’s report on landgrabbing that said 60% of African landgrabs were related to biofuels projects. When challenged on the robustness of their data, their admitted that no groundtruthing took place due to excessive costs related to the activity, and that instead their data was a result of cross-referencing media reports. They also said that the focus in the media on landgrabs related to biofuels rather than for extractive industries or large-scale agriculture for food exports was a likely reason for such a high volume of landgrabs attributed to biofuels.

What is obviously missing from this debate is a clear set of data that is verified on the ground, because only then will policies be developed—and then must be implemented, which is not the case now—to ensure that landgrabbing from all industries comes to an end, rather than just pointing the finger at what appears in the media.

  1. The V0 provides a detailed and comprehensive discussion of the central role of biofuels for high and volatile food prices. Are there further discussions that need to be taken into account?

PANGEA recently analysed the relationship between food prices and biofuels production in sub-Saharan Africa. The full report can be found here

Here some findings from the report:

Between the second half of 2010 and the first half of 2011, international food prices again experienced a sharp rise after having decreased since the dramatic crisis of 2007/08. The FAO food price index rose by 32.7% between June and December 2010, whereas the cereals price index peaked in April 2011 at 178.9, 65.8 points (57.9%) higher than in June 2010. Over the same period some staple food crop prices experienced an even steeper increase. International maize prices almost doubled and wheat prices grew by more than 70% between June 2010 and, respectively, April and May 2011. In August 2011, international sorghum prices were almost twice as high as in June 2010. Rice prices also increased by 36.84% between June 2010 and November 2011.

Among the many factors driving food prices up in 2007/08, biofuels were one of the most debated and controversial: research attributes between about 20% and 75% of food price increases occurred between 2000 and 2008 to the worldwide demand for biofuels (World Bank 2008; IMF 2008; IFPRI 2008). The debate has not ceased and biofuels are yet again believed to be largely responsible for the global food price rises occurred in 2010/11 (Abbott 2011).

These price dynamics, however, mainly refer to commodities traded on international exchanges such as the Chicago Board of Trade. Domestic price dynamics can be completely different as price transmission from international to local markets depends on the extent to which the latter is integrated with the former, as well as on other factors such as the structure of domestic markets, the exchange rate of local currencies against the US dollar and the existence or lack of domestic infrastructure, which determine transaction and transport costs (ODI 2008; OECD 2011; IEEP 2012).

Sub-Saharan Africa is a net importer of food and agricultural commodities. In 2010, an average of 10.46% of food merchandised in the region was imported, ranging between 4.71% in Zambia and 36.10% in the Gambia[1] (World Bank, 2012). Higher food prices may lead to trade imbalances to which Sub-Saharan African countries, who are for the most part low-income, have difficulties to respond. Food price rises are likely to have a particularly strong negative impact on the lives of Sub-Saharan populations: food makes up nearly half of household spending in the region (AfDB 2012), and even in rural areas many households are net buyers of food (IFPRI 2011). However, international trade restrictions are common in Sub-Saharan Africa, and in some cases are likely to block price transmission from international to local markets. Moreover, only certain food crops are imported from overseas, such as rice and wheat; many staple crops, e.g. maize, are produced locally or imported through cross-border trade (IFPRI 2011).

The purpose of this report is hence to examine the link between global demand for biofuels and the 2010/11 food crisis in the Sub-Saharan African region, and to understand to what extent the former has influenced the latter. In order for the analysis to be as comprehensive as possible, this paper builds on both statistical analysis and qualitative research. Food prices from 20 Sub-Saharan African countries have been compared to international commodity prices over the period 2010/11, in order to analyse the degree of price transmission from global to local markets. Along with a description of the production of biofuels in the region, the paper offers an analysis of other factors that have a direct causal link with food price dynamics. PANGEA believes in fact that these factors, namely the low and declining productivity of Sub-Saharan African agriculture coupled with exceptionally unfavourable weather conditions, along with rising international oil prices have been the real causes driving food prices up.

4.    The V0 endorses initiatives which give priority to broad bioenergy strategies for local use in energy poor regions of the world where the potential social gains are large from even small quantities of energy and the impact on land use competition small. Which are the most far-reaching examples of such policies or experiences in practice?The V0 draft report presents a series of policy proposals, which are understood to follow on from the analysis developed in the different chapters. These proposals are still very preliminary and general in character. Do these proposals adequately reflect the analyses developed in the V0 draft? 

PANGEA agrees that there needs to be more focus and investment on small-scale bioenergy production to increase access to energy in rural and off-grid areas, allowing them the development opportunities that are so clear from such activities such as improved access to health care, education, economic development activities, and cleaner home environments for women and children who benefit from clean cooking fuels. Existing projects that demonstrate these benefits include CleanStar Mozambique and Mali Biocarburant.

But to single out only small-scale production for local use is naïve. Developing countries and developed countries alike have the need to include biofuels in their transport fuel mix in order to decarbonise as well as to reduce dependence on oil imports.

More than 95% of gasoline and diesel in Africa are imported, putting a huge strain on individual economies, the economy as a whole, and the viability of every business from multi-nationals down to micro-enterprises. Malawi, as an example, is suffering under the weight of soaring fuel prices due to fuel shortages and a soaring inflation rate - prompted by a 50 percent devaluation of the currency, but the country could benefit enormously by boosting production of the fuel it has produced and used domestically since 1982. Expensive fuels lead to expensive fertiliser, higher input costs in mechanised agriculture, and more expensive transport that keeps farmers from getting their products to market.

Agricultural and other organic waste must be used as feedstock for transportation fuel not only in small-scale projects but also on a larger scale. First generation feedstocks like sugarcane, sugarbeet and wheat offer similar GHG savings to second-generation biofuels, but using technologies that are available in the market now and can be transferred to developing markets that need them. Projects like Addax Bioenergy in Sierra Leone have been working with the local community to produce large-scale ethanol sustainably since the project’s inception, winning awards for innovative ways to engage local populations in the project, while also ensuring land set aside for food production. Green Fuel in Zimbabwe is working through kinks in its project to achieve a more sustainable relationship with its local communities so that it can supply 10% or more of the local fuel demand, increasing energy and food security simultaneously. More sustainable projects must be developed and implemented on a large-scale for both local use and for value-added exports.

Demand for those exports come from policies that stipulate the mandatory blending of biofuels. Voluntary blending targets have been shown to not provide sufficient demand for blending, so mandates must be put in place that ensure decarbonisation of transport while ensuring sustainable energy production and consumption. Otherwise, all that is left is increased use of fossil fuels, a further rising of the planet’s temperature, and a wish and a hope that some day hydrogen fuel cells and second-generation biofuels with save the day while electric cars are charged on national grids powered by coal.

[1] World Bank staff estimates from the Comtrade database maintained by the United Nations Statistics Division.


Land and Water Division FAO, Italy
FSN Forum

I.             Comments with regard to land:

The part on land tenure is done well. For example, the para:

“The justification for such investments lies in the notion of “available” land which is equated with unused and un-owned land. NGO and peasant organization mobilization have exposed this myth and it is now accepted that land which is the object of investment is normally land which is occupied by traditional communities under different forms of communal rights or as State land”.

Is exactly what we have tried to highlight as a result of our field projects and the evidences coming from the discussions stimulated by the  Land Portal initiative (  There is no available land, meaning land without people. Every single square meter of land has some sort of historical right (whose extension might be discussed, but it exists). This means that a serious participatory approach is needed, more than, as advocated by the authors, a simple compliance with the FPIC principles.  As is said later in the report, section on “SOCIAL IMPLICATIONS OF BIOFUELS:

Where profound asymmetries of power and economic resources exist, rights can be routinely trampled on. In addition, opportunism and corruption, which are endemic to modern governments and not the preserve of failed States, can cheat communities out of their rights while formally following the rules of the game. On the other hand, within traditional communities, co-option and opportunism are favored by patriarchal systems of authority. Empowerment, therefore and the promotion of a vigorous civil society are the pre-conditions for the ability to defend and negotiate rights”. (p. 49)

This is what FAO has been doing, through several types of concrete field approaches for both land and forestry communities: I do want to recall our (NRL) approach to Participatory and Negotiated Territorial Development (PNTD) and the Forestry approach  to Community Forestry. Similar approaches also exist for fishery communities.  What they have in common all these approaches is the fact that they start from the recognition of the centrality of the problem of asymmetries of power and therefore do have a pro-active position to work in order to mitigate it. Since this document will have an FAO logo, I do consider that it would be worth recalling what are FAO experiences and proposals, before going to other  proposals, like FPIC, which are certainly more fashion, but who clearly do not pretend to attack the core problem of asymmetries, therefore leaving the problem where it is.

II.            The part regarding the quantification of land and water resources needed for biofuels is not as good:

It is not clear how land and water use for biofuels is quantified. Both references and calculation methods are not clear. It appears that the writers are of the opinion that there are not enough land and water resources to grow more biofuels in the future than already done now. Whether this is true is not substantiated enough by evidence and references. Especially the part on water use for biofuels is weak. The report does not make distinction between irrigated and rainfed agriculture, between consumptive and non-consumptive use, between geographical locations and the different sources of water.

Please find below some more explicit comments on the most relevant sections in the report (focused on water use for biofuels).

Executive summary:

The first paragraph of the Executive summary of the report reads:

If 10% of all transport fuels, to date, were to be achieved through biofuels, this would absorb 26% of all crop production. At present, if we would use the totality of the world´s crops to produce biofuels, it would represent at most only 13% of the world´s primary energy, which, if inefficiencies in appropriation were included, would realistically be closer to 9%, and which in 2050 would only correspond to 4-6% world’s energy. This would further mobilize 85% of the world´s fresh water resources.

The least sentence, that 85% of the World’s fresh water resources is mobilized by crop production, is not true. Currently about 2.7 billion cubic kilometers are being withdrawn for irrigated crop production, which is about 6%. It is not clear to me where these 85% are coming from. Later on in the report (p41), a reference to Foley (2011) is mentioned, but this reference is still to be added to the references. It is likely that evapotranspiration by all agricultural land including, grasslands and production forest is meant, but even then these 85%  seem high. Also, the major part of the evapotranspiration is rainfed and taken directly from the soil and not from lakes, rivers and aquifers which form the world’s fresh water resources.

Policy recommendations:

Draft Policy recommendation 3:

3. The negative experience with jatropha has shown that the pressure on land provoked by biofuels is equally a pressure on water resources. Investments in land are increasingly being understood as simultaneously investments in water. Policy must now catch up with analysis and integrate land and water so that land concessions cannot be made without an evaluation of the impacts of land use on water resources.

Is a correct one in the sense that policies should not be made without an integrated analyses of the impacts of land use on water resources. However, it is not clear what jatropha has to do with it. Jatropha is used in the report as a negative example to show that no adequate production of non-food crops can come from marginal lands (of course this is no surprise to anybody who knows a bit about agricultural production).

Draft policy recommendation 11:

11. On the other hand, the wealth of biofuels case-studies reviewed in our Report shows the importance of shifting from a narrow biofuels to a more comprehensive bioenergy policy approach. In developing countries with vast hinterlands, the mobilization of biomass for different forms of bioenergy can be the most effective development strategy to provide electricity and alternative power for cooking, water management, and local productive facilities in addition to transport fuel.

It is not clear to me how the mobilization of biomass for bioenergy can be an effective development strategy to provide power for water management. No examples are given in the report.

4. Biofuels and land

In “4.1.1. Food and Feed Demand” reference is made to FAO’s perspectives study Agriculture towards 2050. However, no reference is made to the part regarding water use in agriculture. It is clear that the writers are not convinced by the results of this study. In particular the way the potential cropland is calculated (based on the GAEZ-model). According to report:

Yet, the FAO has itself warned that these estimates are overly generous for a variety of reasons. They ignore land with major soil constraints, which according to FAO includes 70% of all the otherwise suitable land in sub-Saharan Africa and Latin America. In addition, as early as 2003, the FAO warned that 60% of this land was covered by forests, protected areas or human settlements.

It would be good to add a reference to substantiate the above mentioned statement. To my knowledge of the GAEZ, soil constraints, forests and human settlements are deducted from potential suitable land.

Further on is written:

What remains rarely receives much mention, but, by process of elimination, the remainder consists of wetter savannas (those savannas capable of crop production) and sparser woodlands. It has become common to view these lands as somehow surplus (Lambin 2011). One joint World Bank/FAO study actively encourages their conversion to food production or bioenergy in sub-Saharan Africa (Morris 2009; Deninger 2011). But tropical savannas and sparse woodlands have large quantities of carbon and high levels of biodiversity (Searchinger 2011b; Gibbs 2008). Their conversion would result in substantial environmental losses.

This statement may be true but it is beyond the scope of the report. The same is true for the statement:

Although the prospect probably exists to expand agricultural land if necessary to meet food needs, that would run counter to global goals to maintain carbon stores to resist global warming.

In “4.1.2 Bioenergy” some calculation are done on how much crop production is necessary for the provision of bioenergy. These calculations are ambiguous. It says that:

producing 10% of the world’s transportation fuel by 2020 would require 26% of the world’s crops today and If 100% of all the world’s harvested biomass were devoted to bioenergy, that would yield probably on the order of 30% of the world’s energy supply today If statement 1 is true, 100% of crop production would provide about 40% of the world’s transportation fuel in 2020. But total energy supply is much more than only transportation fuels, so I cannot imagine how both statements can be true.

In the same section there is the earlier mentioned statement on the 85% of water resources that are withdrawn. Also an explanation is provided on the energy inefficiency of the photosynthesis which is difficult to follow. It is especially not clear how energy content of crops are measured.

On page 47 is written:

Recent research has shown that many of the jatropha projects have now been abandoned or have been replaced by food crops as it is becoming clear that jatropha needs both water and modern inputs if it is to achieve acceptable productivity levels (Friends of the Earth, 2010, African Biodiversity Network, 2010) . Tim Williams (2012), from the International Water Management Institute, has insisted that while water is in fact the key resource, land deals are negotiated without explicitly taking into account the water implications of large-scale projects because land and water are subject to different regulatory systems and different governmental responsibilities. Large-scale projects can lead to water being overdrawn, to the diversion and the drying up of water sources. Women as water providers can be particularly prejudiced as they often have to travel greater distances to find water sources. In addition, large-scale monoculture may modify rainfall patterns.

The part of Tim Williams saying that land deals should take into account explicitly water implications of large scale projects is a very important point. This point should probably be made more explicit, and be placed out of the context of Jatropha and the fact that women have to travel longer distances to fetch water. Also the remark that large scale monoculture may modify rainfall patterns is not relevant here.

Thank you.