Forum global sur la sécurité alimentaire et la nutrition (Forum FSN)

Overview on the EU Renewable Energy Directive and biofuels (30 January 2013)

The European Parliament and the Council adopted in April 2009 a Directive on the promotion of the use of energy from renewable sources ('Renewable Energy Directive') as a part of the EU climate and energy package which aims to combat climate change and increase the EU’s energy security, to promote technological development and innovation, and to provide opportunities for employment and regional development, especially in rural and isolated areas. The Directive includes, besides the 20% overall target for the share of renewable energy in 2020, a 10% target for each Member State for the share of energy from renewable sources in transport in 2020. [1]

The Renewable Energy Directive provides a clear set of sustainability criteria for biofuels to be applied in all EU Member States. Identical provisions are also included in the EU Fuel Quality Directive which establishes minimum specifications for fuels for health and environmental reasons and sets a target for the reduction of life cycle GHG emissions of fuels.[2]

At the EU level there is no regulation as regards the Member State's choice for its renewable energy mix or support instruments. There is no mandate for biofuels at the EU level. The implementation of the Directive including the design of the support schemes to promote the development of renewable energy is the responsibility of the Member States.

The EU biofuels sustainability regime equally applies to domestically produced and imported biofuels. The EU biofuels sustainability criteria require that biofuels save a minimum amount of greenhouse gas (GHG) emissions compared to fossil fuels. Biofuels need to save at least 35% compared to fossil fuels in order to receive the support and/ or to be counted towards the national or EU targets. This threshold will rise to 50% in 2017. In the calculation of the life cycle greenhouse gas emissions, not only carbon dioxide is included, but also methane (CH4) and di-nitrous oxide (N2O) are included (both stronger greenhouse gases than CO2).

Moreover, restrictions with respect to the land used for the cultivation of biofuels apply. These are mainly aimed at the preservation of biodiversity and the protection of carbon rich soils and require that biofuels are not made from raw material from land with high biodiversity value or high carbon stocks such as forests and peatland. Implementation of these criteria is enforced by the Member States where the biofuels are used.

A number of environmental and social issues related to the production of biofuels, including environment, food security aspects and the use of water, land and soil resources, are additionally addressed through voluntary biofuels certification schemes and the monitoring and reporting requirements. Most of the 13 voluntary schemes, that are recognised by the Commission today and that are active in non-EU countries, cover also additional environmental issues, such as water, air and soil protection, as well as social issues, including land use rights, food security etc.

The first biennial report of the Commission will be published shortly. The report will be made available on the Commission web site dedicated to renewable energy: http://ec.europa.eu/energy/renewables/index_en.htm

At the EU level support is provided for facilitation of development and deployment of technologies for large scale production of advanced biofuels from non-food-crops as well as for the transport sector technologies using other sources of renewable energy such as electric cars and cars using hydrogen or biomethane.

In addition, on 17 October 2012, following the obligation under the Renewable Energy Directive that was adopted in 2009, the Commission adopted a proposal to limit global land conversion related to biofuel production, and raise the climate benefits of biofuels used in the EU.[3] The Commission proposes to limit the amount of 1st generation biofuels (including from maize) that can count towards the Renewable Energy Directive targets to 5% of overall energy consumption in transport. The Commission has also proposed to provide additional incentives for advanced biofuels from non-food crops that do not create an additional demand for land. The proposal will now be discussed between the co-legislators in the Parliament and the Council.

1. Introductory Comments

Germany highly welcomes the opportunity to comment on the HLPE V0-Draft reviewing biofuel policies and the challenges and opportunities that they may represent for food security. Coming from a human rights approach and taking into account obligations embedded within the human right to adequate food, Germany supports biofuel production where it is socially, economically and environmentally sustainable.

Overall, the report provides a solid assessment of biofuel production implications on food security. It further attempts to balance its findings, especially with regard to policy recommendations.

Nevertheless, Germany would stress the need include the human rights based approach to food security. We therefore recommend including the human right to adequate food in the summary and introduction as a human rights based framework in the discussion on food security as well as referring to core human rights treaties, including among others

• The Voluntary Guidelines for the Progressive Realization of the Right to Adequate Food in the Context of National Food Security (with regard to the topic biofuels and food security especially Guideline 8)
• The Voluntary Guidelines for the Responsible Governance of Tenure of Land, Fisheries and Forests in the Context of National Food Security

By referring to these international documents a stronger human rights perspective on Biofuels and Land would be included in the study as well.

However, the science-based comparative literature analysis in general provides the impression of being one-sided: The study concludes that biofuels are the solely or predominantly responsible cause for food insecurity, price volatility and discrimination against women. With regard to this conclusion, Germany witnesses a dissent with existing science-based literature. So far, adequate proof and precise impact analysis is lacking within the study. Respective citation is not enough to assume linkages and above all correlations between biofuels and e.g. gender inequality. For example, the gender dimension of biofuels expansion analysed in chapter 5.2. is mainly based on cited sources which demonstrated an impact of palm oil expansion on women´s land rights. Although a certain evidence for this impact is well comprehensible, the main driver behind is not automatically nor exclusively a higher demand for biofuel. On the contrary, the major drivers for palm oil expansion in the cited case study of Indonesia are increasing food and feed demands, knowing that much less than 10% of palm oil is used for biofuels. Consequently, chapter 5.2 should be re rephrased in “the Gender Dimension of Palm Oil Expansion (Case Study West Kalimantan)”.

It seems, the study is taking for granted the validity of the thesis that biofuels especially in the EU contribute to food insecurity without sufficiently examining the actual magnitude of biofuel production impacts on food security. It would have been relevant to investigate the capacity of the sustainability system of the European Renewable Energy Directive to prevent harmful effects on the environment and food security. 

Germany therefore encourages providing a more balanced literature analysis and more detailed insights about the specific impact chains of the various factors influencing price volatility, food insecurity and gender inequality, such as changing consumer behavior, demographic growth or weather related supply volatility (floods, fires etc.) in order to do justice to the complex causes of these phenomena in a holistic approach.

Considering the impacts of biofuel production on increased pressure on land, Germany perceives the report findings as adequate to reflect the realities in target countries.  

Last, but not least, Germany calls for correction on the first page of the policy recommendation in the executive summary: the consent referred to has to be named according to the agreed UN resolution. Hence, wording has to be “free, prior and informed consent”.

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

The report’s policy conjuncture can only be partly agreed on. In general, there are some inaccuracies in the study. On the one hand, some of the data used is quite old. On the other hand, the report contains striking mistakes. Page 14 as well as the executive summary claim that the EU has already issued a directive modifying its mandated targets for first-generation biofuels from 10% to 5%. However, this is not correct. A proposal has been made by the European Commission which still has to go through the approval process by the Council and Parliament.

Additionally, recent suits against the mandated targets for biofuels of 15% in the USA were overruled. Hence, the USA are most likely continuing their biofuel promotion.

It has to be kept in mind as well that some of the negative experiences with regard to various legal regulations worldwide, especially in Brazil and South Africa, can be related to specific mistakes and shortcomings within the respective policy designs. Coming from these examples, the study should avoid concluding on demanding the fully abolishment of biofuel promotion. Often, undesirable development can be traced, as in many other cases of investment projects, to weak governance structures within the targeted countries.

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 scope taken into account is broad and adequate.

However, Germany would like to propose a few additions:

• The study focuses preliminary on land in Africa. Available land with good soil quality that was used for agriculture but is now fallowed, such as in Eastern Europe, is not considered at all. Hence, considering the potential for agricultural yield increase not just in Africa, but as well in other parts of the world would add to the quality of the report.
• A clearer definition of “degraded land” and possible use of this land by adjusted plant species would be welcomed.

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?

For the general impression on this question please consider the comments made under the introductory remarks with regard to the science-based literature analysis.

More specifically the study should take into account as well:

• regional market prices are not always closely linked, but sometimes show individual price behavior
• Differentiation between short and long term impacts of price increases/volatility
• The two-sided impact of price increases: the study offers an uncritical as well as undifferentiated rating of price increases as negative. Yet, price increases may also create incentives for sustainable agricultural production and increased standard of living especially for rural populations.
• The following topics also influencing prices should be further elaborated in the study: increased costs of production, oil price development, speculations, Dollar exchange rate, weather related yield volatility, demographic growth, changing pattern of consumption, insufficient storage capacities.
• Following topics influencing prices yet not at all listed in the report should also be included: change of agricultural and trade policies, production estimated for future yields, financial crisis, yield increases, wars and conflicts.
• Further, the following topics should be elaborated in more detail as well: the impact of supply variations on agricultural commodity prices with special attention given to weather implications, “thinness of markets” (e.g. rise markets during the 2007/2008 agricultural crisis) and insufficient market transparency.

The report briefly touches on the topic of speculations influencing food price volatility. However, findings are not consistent: p.35/3.3.4 states: “on the other hand, an increase in production costs due to the rise in the cost of energy, poor weather (prior to 2012), and speculation have not played a significant role.” Contradictory, the preceding paragraph states “speculations may possibly have played a secondary role”. In order to resolve this inconsistency Germany proposed the following wording: “on the other hand, an increase in production costs due to the rise in the cost of energy, and poor weather (prior to 2012) have not played a significant role. Speculation is probably not a reason for the rising prices, but it may be a secondary reason for more volatility on the short run.”

1. 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?

Due to its prior assessment of biofuel production impacts on the food security of the local population, Germany highly encourages to highlight the BEFS (Bioenergy and Food Security) approach of FAO. Projects on sustainable biomass cultivation by the GIZ (Deutsche Gesellschaft für Internationale Zusammenarbeit – GIZ GmbH) should be considered as well.

Another project that might be worth considering is the BMZ-funded Integrated Food Security Program Mulanje in Malawi (IFSP: 1996-2004) developed an integrated “food and fuel” concept which strengthened synergies between food production and biomass fuel supply. This concept has been further elaborated by the Program for Biomass Energy Conservation (ProBEC) between 2005-2010. This successful example has been taken up by the FAO in the Integrated Food and Energy Systems (IFES) approach (see http://www.fao.org/energy/78517/en/).

Dear HLPE Project Team,

We very much welcome the opportunity to provide input to the latest version of your Biofuels and Food Security report. Please find attached a summary of comments which are the result of a review coordinated by Dr Frank Rosillo-Calle the Imperial College Centre for Energy Policy and Technology (ICEPT).

We hope that our comments and literature recommendation will be useful to you and inform future iterations of this analysis. Do let us know if you need further clarifications or require additional input.

Kind regards,

Nicole Kalas (Doctoral Researcher)

Frank Rosillo-Calle, PhD (Honorary Senior Research Fellow)

Rocio Diaz-Chavez , PhD (Research Fellow)

Raphael Slade, PhD (Research Fellow)

Alexandre Strapasson (Doctoral Researcher)

Dear Colleagues,

We appreciate the opportunity to comment on the HLPE’s zero-draft consultation paper (dated 9 January 2013) on Biofuels and Food Security. We have several general comments to offer.

• First, the report focuses primarily on liquid biofuels for transport; it should be noted that different forms of bioenergy for different purposes may well have very different implications for food security.

• Second, many important statements are made without citing references (including key FAO references on the topic), and arguments are difficult to follow in some places.

• Third, the report devotes considerable attention to the price impacts of biofuels, but does not sufficiently address the impacts of expanded biofuel production on farmers’ incomes. Likewise the report does not distinguish clearly enough between short-term and longer-term impacts, and thus paints an incomplete picture of impacts on food security.

• Fourth, we note a disconnect between the main body of the report, which is largely critical of biofuels (or at least of first-generation liquid biofuels for transport), and the Draft Policy Recommendations, which are broader and more balanced. There are sharply divergent views on this topic, which is why it deserves careful attention by the HLPE and the CFS; these will not likely be resolved by the HLPE or the CFS, but the paper should nevertheless provide a balanced assessment of both sides of the argument.

These and other points are elaborated in the specific comments attached. We hope they are useful in revising the paper to provide a more nuanced and complete discussion of impacts on food security.

Many thanks to Seth Meyer for his work on this.

Best regards,

Kostas

The 2011 Report on “Price volatility and food security” by the HLPE on Food Security and Nutrition[1] provided well-researched and high-quality evidence about the role of biofuels in recent food price rises and price volatility.

We had therefore anticipated that the draft report “Biofuels and Food Security” by the HLPE on Food Security and Nutrition would build on and further develop the evidence collated for the 2011 report. Instead, we have been deeply disappointed by the low quality of evidence and inaccuracies contained within this draft report.  While some paragraphs and statements are based on convincing evidence, so many are not that we believe the report needs to be sent back to be substantially re-written before being put out to public consultation again.  Below are examples of some of the serious flaws we have found in the report followed by key concerns about the draft recommendations. 

The report opens with a paragraph that summarizes some of the in principle reasons why biofuels could never meet more than a fraction of current energy demand without causing very large-scale negative impacts. In the executive summary it is stated: “one can assume that bioenergy cannot provide a significant source of the world’s total energy”. Yet these facts have not informed the rest of the report or the draft recommendations with any consistency.

Many of the recommendations contradict or undermine the conclusions of other sections of the report. Several of them are extremely weak or have taken no account of the experience of biofuels and simply repeat hopes that policy reforms can address deep-seated inequalities of power and access in the short term. However, we do not believe that strengthening or adjusting them alone would be the answer.  Credible recommendations must be based on a convincing strong evidence base and this has not been consistently provided by the report.  This is why we believe the entire report, not just the recommendations, requires rewriting.

The report seeks to cover broad issues such as biofuels role in rural development in such a cursory manner that they operate simply as misleading assertions that biofuels can work in the future if certain changes are made. This has been a regular feature of biofuels discussions to date, contributing to biofuel policy lock-in. We refer in particular to paragraph 4.2.4. The Importance of Production Typologies for Identification of Policy Options and recommendation 8, which should be removed.

Perhaps most crucially, we believe that the recommendations and conclusions of the report should be restricted to liquid biofuels and that claims such as those made in paragraphs 5.4 must be omitted entirely. Below are two further examples that illustrate why we believe that the brief discussion and conclusions in and based on paragraph 5.4 should have no place in an evidence-based report by the HLPE.

The report misrepresents current EU biofuels policy

Chapter 1.5 of the report, “Land-Use Change provokes Changes in EU targets and Influences US Policy”, implies that there has been a change in EU biofuels targets, following a new directive “issued by the EU” in October 2012.  It discusses potentially major changes to global biofuels investment which the authors believe likely to follow from this alleged EU decision.  Draft recommendation 1 also claims that a “recent EU Directive” has moved towards “controlling the growth of biofuels markets”. 

This is factually wrong.  What happened in October 2012 is that the European Commission, in October 2012 published a proposal for a new directive which, if approved and enacted, would make some changes to the Renewable Energy Directive and Fuel Quality Directive in relation to biofuels.[2] This proposal has not even been considered by the European Parliament or the European Council and any policy decision could be at least another year away.  Furthermore, even if the published proposal was adopted unchanged –which is highly unlikely – the policy implications would not be nearly as far-reaching as the authors of this draft report appear to believe.  Not only is the 10% renewable energy for transport target retained in the Renewable Energy Directive (with National Renewable Energy Action Plans showing that member states anticipate over 90% of this to be met from biofuels), but all first-generation biofuels would still count fully towards the 6% greenhouse gas reduction mandate established by the Fuel Quality Directive (about equal to a 10% energy content biofuels target). 

Such a major misunderstanding of EU policy itself puts the reliability and accuracy of the report into question yet, as the examples below show, this is by no means the only significant flaw in the report.

Separately, we note that the optimistic conclusions about this supposed ‘policy change’ are contradicted by observations elsewhere in the report that non-food biofuels are just as problematic in terms of land use and competition with food and that crops are increasingly being used ‘flexibly’ for different purposes. To distinguish between food and non-food crops for biofuel policy is not helpful as the authors of the report point out elsewhere, for example in draft recommendation 9.

The report also misrepresents current US biofuels policy

The credibility of the report is further undermined by the fact that it misrepresents not just current EU but also current US biofuels policy.  The report contains several references to US blenders’ tax credit for ethanol that they claim remains in place.  The authors must have been unaware that this tax credit, which had amounted to an annual $6 billion subsidy for US corn ethanol, expired at the end of 2011. Unlike the US tax credit for biodiesel, it has not been reinstated.

A controversial conclusion about the role of subsidies in US biofuels market is based on very limited and selective literature citations.

The draft recommendations state: “Our Report concludes, however that in the context of persistent high oil prices, biofuels from maize in the US and from sugar-cane in Brazil can be, for different reasons, market competitive.” In other words, the report suggests that especially US ethanol no longer depends on an artificial market, i.e. on subsidies (with mandatory blending identified as a subsidy). The market-competitiveness of biofuels, and especially US corn ethanol (whose impacts on global cereal prices are particularly well-established) would not justify the continuation of US biofuels subsidies, and the authors do not suggest that it does.  However, it would justify the authors’ conclusion that “in this situation, we must advance beyond the discussion of mandates and subsidies to include mechanisms for controlling the growth of biofuels markets”.  The draft recommendation is largely based on a lengthy discussion in Annex 3, which points to the significance of this ‘finding’: “A disturbing implication of the link established between the energy and agricultural commodity markets is that the advocated elimination or reduction on the size of the support to biofuel production by development and civil society organizations may not have as large an impact in reducing commodity prices as they might hope.”

This controversial conclusion is based on very few citations and primarily relies on a single paper published by the International Centre for Trade and Sustainable Development, written by Bruce Babcock.[3]  This is the only report cited which focuses on analyzing the effect of US biofuel subsidies, including the blending mandate, on the economic viability and profitability of corn ethanol and on grain prices.  Babcock concluded that the effect of corn ethanol subsidies on grain prices has been modest compared to the effects of market-driven corn ethanol expansion on corn and other commodity as well as food prices.  He also concluded that corn ethanol expansion would have happened regardless of subsidies, though it may have happened slightly more slowly.  Babcock’s methodology relies on modeling price developments and decision-making according to short-term fluctuations in prices and profit margins.  Babcock assumed that corn ethanol expansion ahead of the regularly increasing blending mandate (Renewable Fuel Standard or RFS) had to be drive by market factors rather than by that mandate.  Yet other researchers, using different methodologies and assumptions, have come to quite different conclusions in relation to the RFS mandate.

For example a 2012 paper by Colin Carter, Gordon Rausser and Aaron Smith[4] concludes that, in the absence of the RFS ethanol mandate, corn prices would have been 30% lower between 2006 and 2011 and that they would have been 40% lower in 2012.  This paper argues that ethanol production and price developments, including the refinery construction boom from 2006-09 cannot be explained without looking at inventory dynamics, i.e. at producers ramping up production in anticipation of the RFS mandate increasing.  The authors point out that a USDA 10-year projection in 2007 accurately predicted ethanol developments over the next three years when it took account of producers preparing for the mandate to be increased.  In 2006, the USDA projection had ignored such a response and underestimated ethanol production considerably. 

This is a very different approach and conclusion from that chosen by the authors of this draft report.  We are seriously concerned that a far-reaching conclusion about the role of artificial markets in boosting global biofuel production and demand has been reached without a critical and comprehensive discussion of the literature and instead relies primarily on single source.

“Bioenergy for Development” – More conclusions reached without relevant evidence

In recommendation 11, the report speaks of the need to move beyond considering biofuels to bioenergy generally, but it does so in the context of ‘developing countries with vast hinterlands’ where, it claims, the mobilization of biomass for bioenergy policies for energy could be positive.  This recommendation is based largely on the discussion “Biofuels and Bioenergy for Development” in paragraph 5.4.of the report.

We believe that there is a serious need to discuss the effects not just of biofuels but of the cumulative impacts of growing bioenergy demands including on food, land rights, biodiversity and fresh water.  Such a discussion would need to look, for example, at the likely effects of EU and North American policies to stimulate the demand for wood pellets and woodchips for power stations.  For example, a 2012 EU Parliamentary Report, Impact of EU Bioenergy Policy on Developing Countries[5] warns that EU member states subsidies for biomass threaten to increase land conflicts in regions such as Central and West Africa from which biomass is expected to be sourced in future, as well as serious long-term impacts on food security.  The cumulative impacts of different types of bioenergy demands and markets would thus clearly merit a separate report. 

We are seriously concerned, however, to see the report include a perfunctory discussion of the potential ‘benefits’ of bioenergy in rural areas in developing countries, based on little or no evidence.  This has not been put in the context of the growing EU and North American demand for biomass for power stations. Developed countries are competing for the same resources that would be required for bioenergy expansion in developing countries in the international trade arena and this demand is shaping policy everywhere. Experience with biofuels shows that declared policy objectives of improving energy access in developing countries are easily pushed aside by investors and often policy makers in favour of supplying fast-growing, lucrative and guaranteed Northern markets.  Biomass expansion threatens to repeat this experience.

As we noted above, given that virtually all of the evidence considered in this report relates to liquid biofuels, we believe that recommendations and conclusions should be restricted to those and that claims such as those made in paragraph 5.4 must be omitted entirely. Here are two further examples that illustrate why we believe that the brief discussion and conclusions in and based on paragraph 5.4 should have no place in an evidence-based report by the HLPE.

+ Paragraph 5.4 states: “Alongside these large-scale investments, NGOs, private foundations and cooperation programs have been promoting a wider conception of biomass use within the framework of sustainable development, local, rural and urban. Initiatives such as COMPETE, Probec, Re-impact have focused on the multiple uses of biomass for electricity and power generation, for alternative sources of heating and cooking and also for local transport (German et al, 2010, UNDESA, 2007. Maltitz  & Stafford, 2010). Many of these projects are specifically geared to the needs of rural communities “off the grid”, which may be quite small now in some regions, such as Latin America, but are often a majority phenomenon in Africa and Asia.”

The citations suggest that those three sources have looked at the impacts of the three initiatives listed above and found them to have positive effects.  This, however, is not the case.  All three sources relate to liquid biofuels only.  One (Maltitz & Stafford 2010) includes no case studies.  Another (German et al 2010) looks at six case studies of biofuel projects involving industrial plantations and outgrowers and notes some highly negative effects for example of an outgrower biofuel scheme in Zambia which led to 22% higher deforestation.  Its most ‘positive’ observations related to jatropha which had been planted with high expectations and promises but which has since been shown to have been a virtually universal failure.  The third source (UNDESA 2007), now very outdated, lists a series of biofuel project intentions, without any follow-up and also exhibits strong faith in the potential of jatropha which, as this HLPE draft agrees elsewhere, was misplaced.  None of them mention any of the three initiatives listed in the paragraph above and thus no actual evidence of such projects meeting the needs of rural off-grid communities has been provided. 

          + “Of particular significance are adaptable technologies for cooking, heating and water management. These address themselves to the central issues of health and the subordinate position of women. New cooking technologies have the wider significance of applying equally to the urban population, a large proportion of whom continue to rely on wood and charcoal for cooking, (Slaski & Thuber, 2009, Rai & McDonald, 2009; WHO, 2006; www.worldbanck.org/hnp).”

The serious impact of energy poverty and reliance on polluting and inefficient forms of biomass cooking are beyond dispute.  Yet demonstrating the need for better energy choices is not the same as demonstrating that ‘solutions’ such as supposedly clean and efficient biomass stoves actually work.  Studies now show that various stoves promoted as offering the benefits referred to in the HLPE draft report are not meeting such expectations and that modern stoves ‘expected’ to improve women’s health may not actually do so[6].  Similarly disappointing evidence has been compiled in relation to small-scale biomass gasification which has been widely promoted to meet the very bioenergy policy objectives for developing countries supported in this draft report.  According to a report commissioned by the German government: “In general, the small-scale power-gasifier technology proved to be unreliable and expensive. Even the few cases where the gasifier plants performed quite well over a prolonged period experienced many technical problems during the first one or two years”[7]. 

These examples show how dangerous policy recommendations about bioenergy which are based on general principles but not on evidence can be and why they must be omitted from this report.

Contradictions between different observations and recommendations/conclusions in the report:

The report summarises some of the in principle concerns why biofuels could never meet more than a tiny fraction of current energy demand without causing very large-scale negative impacts. For example, the opening paragraph states: “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.”  Elsewhere in the Executive Summary, it explains: “The fundamental problem lies in the relative inefficiency of biomass for energy as plants are unlikely to transform more than 0.5% of solar energy into biomass energy, with a the final fuel energy yield down to only 0.1-0.2%.    When food, feed, energy and carbon storage demands have to be considered jointly, given the orders of magnitude at stake, one can assume that bioenergy cannot provide a significant source of the world’s total energy.”   (We note here that on page 2 a 3% figure is cited for photosynthetic efficiency, contrary to the above cited quote and contrary to what is commonly accepted – another example of inaccuracies in the report.) 

Yet these facts appear not to have informed the rest of the report and the draft recommendations with any consistency.  Given the low energy density and very large land and water requirements of biofuels identified, why do the authors suggest that they can nonetheless play a significant role in ‘sustainable development’ with the right policy framework?  Why do they support the development of biofuels standards and frameworks aimed at a supposedly ‘sustainable’ expansion of biofuels worldwide? Those claims appear to repeat old assumptions that date from the very early days of biofuel promotion and which have helped to keep policy locked in to the pro-biofuel path.

Poor and partially flawed evidence citations in relation to second-generation, algal and jatropha biofuels

Chapter 2.3 looks at biomass-to-liquids biofuels/biorefineries, jatropha and algal biofuel. For example, authors merely say that biorefineries “demand major advances in conversion techniques and feedstock processing” without identifying what the hurdles are and why nobody (despite billions of dollars in investments and high levels of public subsidies) appears to have been able to achieve a positive energy balance from biomass-to-liquids fuels.  The role of synthetic biology/genetic engineering in second generation biofuel research and development and the implications of this have not been acknowledged in any way. Not one literature source is cited in relation to second generation biofuel conversion.

Similarly, the paragraph on algae contains only scant information about the problems and concerns associated with it and cites not a single of the studies investigating those, such as a study that shows that the water-footprint and energy-footprint of algal biofuels with current technology would be even worse than that of any existing biofuels.[8]

In relation to jatropha, the authors acknowledge that it has been ‘so far a failure’ but nonetheless claim that “jatropha had the agronomic advantages initially identified”, attributing the failure to economic requirements for high yields.  Yet there is comprehensive evidence that such a statement – i.e. one that widely-made claims about agronomic advantages of jatropha were correct – is untenable.  A 2009 report published by the World Agroforestry Centre[9], for example found: “The basic agronomy of growing Jatropha as a plantation crop, instead of as a minor component of an agroforestry scheme, is not well understood or documented.” It adds to other evidence that claimed ‘agronomic advantages’ such as supposed resilience to pests and diseases, low water requirements and resilience have so far been non-existent.  Jatropha has been shown to be vulnerable to pests and diseases, susceptible to large-scale crop failures when grown in monocultures and requiring more water than most other biofuel crops.[10]  

Comments on draft recommendations:

The draft recommendations are based on the wider discussions in the report which, as we have shown above, are in parts based on an insufficient, selectively cited and at times clearly inaccurate evidence base.  This is why we believe the report itself needs to be re-thought and re-written, not simply the draft recommendations.

Nonetheless we would like to comment on some of those draft recommendations, and especially the contradictions between some of these recommendations.

Recommendation 1: This states that there is “enough evidence to call in question the use of mandates/targets together with subsidies and tariffs where these artificially stimulate biofuels production” but also says: “We must advance beyond the discussion of mandates and subsidies to include mechanisms for controlling the growth of biofuels markets”.  We have shown above that this is largely derived from the authors’ conclusion that the US corn ethanol market no longer depends on subsidies (including the Renewable Fuel Standard mandate) and that that conclusion is based on very limited and selectively cited evidence.  The conclusion thus appears highly premature.  On the other hand, the report cites no evidence to support the continued existence of biofuel mandates/targets and subsidies, particularly in North America and Europe.  We thus cannot understand why the authors do not call outright for such incentives to be abolished – after all, the fact that a particular biofuels mandate or subsidy might not actually be effective in ‘artificially stimulating biofuels production’ is not a reason to retain it.

We thus believe that the report should call for an end to mandates and all other subsidies and incentives, which work singly and together to provide a secure environment to encourage continuing investment in biofuels. Indeed, ideally the report could go further and set broader parameters for a vital debate by calling for measures to stop land-grabbing and genuinely address the serious challenges we face regarding food, biodiversity, water, soils and climate, with over-consumption of energy, agricultural goods and wood in the global North being a main cause of those crises.

Recommendation 2: “The principle of prior, informed consent and full participation of all concerned in land investment deals must be effectively implemented as preconditions for any land deals.”  Firstly, the vital word ‘free’ is missing, and as far as Indigenous Peoples are affected this would be in contradiction with the UN Declaration on the Rights of Indigenous Peoples. Secondly general support for the principle of Free, Prior and Informed Consent, which has proven to be very challenging to implement in practice, is not sufficient for addressing the fact that rights to millions of hectares of land in developing countries are being transferred to companies seeking to grow biofuel feedstocks, usually for Northern markets. Those land grabs are happening in a context of huge asymmetries of power and of many governments being complicit in handing over land.  Trying to set conditions for biofuel land grabs avoids the question whether such transactions can ever be justified (in view, for example of the in principle problems with biofuels highlighted in the Executive Summary).  It thus delays action and thus perpetuates the unjust and harmful process of land grabbing.

Recommendation 3: This calls for land concessions being conditional on an evaluation of the impacts of land use on water resources.  Please see our concerns expressed above about conditions for biofuel land transactions.  We would also point out that especially for jatropha many reports promising low impact on water resources were published and used to justify jatropha concessions, yet jatropha has since been shown to require even more water than many other biofuel feedstocks.  This illustrates how difficult it is to base such evaluations on actual evidence instead of assumptions, especially when relatively new crops or even technologies are promoted (e.g. in the context of second generation biofuels like genetically engineered trees).

Recommendation 4: “Policies must ensure that women participate fully in land negotiations and that their land ownership rights are recognized.” See our comments above.  Furthermore, women are far less likely to have formal land titles in the first place and there are other major and deep-seated social, cultural and political barriers to women being able to participate fully in such negotiations.  This call is thus inadequate for addressing women’s special vulnerability to land-grabs. To address the unequal rights of women requires societal changes that cannot be brought about with a rapid policy fix. The proposed recommendation thus does not credibly address the issues.

Recommendation 5: “Adhesion to the broadly-owned RAI principles, envisaged in the CFS consultation process, and to the voluntary guidelines should be established as a precondition for participating in land deals involving biofuels production plans.” Again, please see our general comments above.  Furthermore, the CFS-RAI process has only just begun and no agreement has been reached, which means that there are as yet no CFS-RAI principles to be endorsed.  The voluntary guidelines on land tenure are weak in relation to markets, investments and redistributive reform (i.e. chapter 4 of the Guidelines).

Recommendation 6: This supports mandatory biofuel certification based on multi-stakeholder, participative and transparent certification schemes.  This recommendation is based on Section 5.3 of the report which we believe to be a very cursory and deeply flawed discussion. A certification scheme could at most address the quality of a certain product, it cannot never address the quantity.  By definition, certification schemes are unable to address indirect land use change impacts, impacts on food prices, or other problems related to the quantity rather than the quality of biofuel production. Nor do the authors examine in how far voluntary certification ‘principles’ are being or can be enforced, especially in the many countries that have shown they lack the capacity to monitor the implementation of, and enforce legally binding and non-legally binding standards.  By defining EU biofuel certification as a regulatory instrument, they ignore the fact that the verification procedure of these certification schemes relies entirely on market transactions between two private companies – in this case a company purchasing biofuels paying a consultancy company for a biofuel ‘sustainability’ certificate.  There is no regulatory oversight or independent auditing of such certificates, i.e. there are no independent checks by public authorities as to whether principles and criteria set out in these certification schemes have indeed been met.  The authors warn in this respect that: “A further limitation of certification schemes is the difficulty (cost, logistics) of ensuring enforcement.” In reality, neither the EU biofuels criteria nor any of the other certification schemes which have been or are being developed, such as the Roundtable on Sustainable Biofuels foresee any enforcement. The fact that the authors’ concern is limited to costs and logistics indicates to us a lack of awareness of the complete absence of independent enforcement and verification by regulatory authorities of these, often very controversial, private sector-driven schemes.

Recommendation 7: This supports certification of broader commodity markets.  Please see our concerns under Recommendation 6.  No evidence has been provided to show that sustainability certification schemes have ever succeeded in preventing or even reducing any of the serious negative impacts of different types of monoculture plantations, nor that this approach can work in future.  Nor are we aware that any such evidence exists. To call to increase the reach of certification schemes to cover broader commodity markets when there is no evidence that such schemes have tackled or are even able to tackle any of the problems associated with the expansion of biofuels and monoculture plantations in general appears misguided.   Overall, we are deeply concerned that calls for different or ‘better’ certification’ have long delayed any action to tackle the demand for biofuels and especially the targets, subsidies and other incentives.  Given the scale of the evidence of the harm caused by biofuel policies already, no further delay through expanding ‘certification’ must be allowed.

Recommendation 8: “We have suggested in our Report that the elaboration of typologies of countries’ situations based on land availability, population density and per capita income can provide a preliminary orientation on the advisability of developing a biofuels policy and the type of policies which would be most appropriate.”  This relates to 4.2.4 of the report. As we have pointed out above, this recommendation appears based on the assumption that shifting biofuel policies in a way that “gives priority to rural development goals, to the objectives of energy security and is premised on strategies for sustainable land use” can make the promotion of biofuels desirable.  This completely contradicts the observations on the fundamental problems with biofuels for example in the Executive Summary.  Furthermore, we cannot see how such national policies could be effectively implemented in the context of the current existing global trade and market in biofuels.

Recommendation 9: “Non-food-competing crops for biofuels should, therefore, be assessed with the same rigor with respect to their direct and indirect food security impact as food-competing feedstocks, since they also compete for land, water, labor, capital and other food-related inputs and investments.”  The observation that the impacts of biofuels from non-food crops will be no less severe than those of biofuels from food crops is correct and essential (it also applies to tree plantations for biomass electricity).  What is needed, however, is not simply better ‘assessment’ but urgent and effective policy changes based on that observation. The report fails to make a concrete recommendation in this respect. Instead it fully contradicts these conclusions with  recommendation 11.

Recommendation 10: This cautions against reliance on second-generation biofuels and calls for ‘alternative policy measures’, such as improvements in fuel efficiency.  This demand is essential and we believe needs to go further to include significant overall reductions in energy use and other consumption, particularly in industrialised countries. 

Recommendation 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.” As we have shown above, the report provides no evidence whatsoever to back up this recommendation.  Rather, under recommendation 9 and 10 it reaches opposite conclusions about broadening the scope biofuel policies. A report which only cites evidence about biofuels should not be making recommendations about supposedly ‘positive’ other types of bioenergy. 

Important areas not covered by the report:

We would recommend that a new draft report should look at additional issues such as:

+ Repeating patterns of biofuel policy developments: It would seem important to investigate in how far policies supporting biofuel expansion have been kept in place due to corporate and other economic interests, once negative impacts of first generation biofuels became widely acknowledged, for example through yet to be substantiated promises of next generation biofuels and how ‘policy lock in’ is being entrenched as more countries adopt biofuel mandates.

+ The report suggests that in land investment deals, customary rights are generally exchanged for leases which then, instead of reverting to communities, may become state land.  This would appear to merit further investigation and evidence.

+ The report mentions that “although the IFC considers that involuntary resettlement should be avoided, it recognizes that it may be unavoidable…”. 

There is a growing tendency to use assertions about major challenges e.g. the asserted ‘need to feed 9 billion people in the context of rapid climate change’ and the thus implied need to make agriculture “more intensive, efficient and smart” as a justification to further undermine and destroy ‘inefficient’ small scale farming, community rights to land, food and water. The report could usefully critique this.

Conclusion:

For the reasons set out above, we believe that there are such serious concerns over inaccuracies, contradictory conclusions, and key conclusions being based on scant and selectively cited evidence if any in the report that it requires to be entirely re-written prior to a new public consultation.

FIAN is an international human rights organization that has advocated for the realization of the right to adequate food for more than 25 years. FIAN has its International Secretariat in Heidelberg (Germany) and exercises its consultative status with the United Nations through its permanent representation in Geneva.

EuropAfrica – Towards Food Sovereignty is a campaign which brings African farmers’organizations platforms (from West, Central and East) Africa and European civil society together. The aim of this initiative is to address the most important challenges in the filed of food governance and international cooperation by facilitating several opportunities for reflection and joint action.

Introductory comment

 We congratulate the HLPE for its work and in particular welcome the work accomplished for the zero draft of the report on Biofuels and Food Security. The current expansion of agrofuel production has considerable impacts all over the world. FIAN has documented several cases of violations of the right to adequate food, especially of small-scale food producers, in many countries around the world, linked to agrofuel expansion. In the context of ongoing debates on the subject, we welcome the HLPE’s efforts to produce an assessment of the impacts of agrofuels on food security and nutrition.

We especially welcome the insights of the present zero draft on the technological development as they are highly relevant for future food security, the right to food and related needs for global governance. This includes both the discussion on flexible crops and the second generation agrofuels. At the same time, we are concerned that the zero draft does not apply a human rights framework, and especially a right to food framework. This is in contrast to the fact that the human rights framework has (a) informed the agrofuel debate on national and global level and contributed to gain substantive insights on the linkages between agrofuel expansion and food security. In addition, we would like to remind the HLPE that (b) the CFS is founded on the human right to food. In its reform document, it is clearly stated that the CFS vision is based on the progressive realization of the right to adequate food. The overarching goal of the progressive realization of the right to adequate food has recently been reaffirmed in the Global Strategic Framework on Food Security and Nutrition (GSF), adopted by the CFS in its 39th session in 2012.

Based on this overall perspective, FIAN and EuropAfrica would like to recommend considering the following aspects:

Include the human right to adequate food in its analysis and recommendations

This allows identifying concrete human rights violations and related responsibilities according to international human rights law.

In particular, we recommend the following elements:

1 We recommend including the human right to adequate food framework in the discussion on food security (in the summary and introduction).

2 The study should refer to core human rights treaties (inter alia the Universal Declaration of Human Rights (UDHR), the International Covenant in Economic, Social and Cultural Rights (ICESCR), the International Covenant on Political and Civil Rights (ICPCR), conventions of the International Labor Organization (ILO)) and substantially include core human rights documents, including:

2.1 The Voluntary Guidelines for the Progressive Realization of the Right to Adequate Food in the Context of National Food Security (especially Guideline 8).

2.2 The Voluntary Guidelines for the Responsible Governance of Tenure of Land, Fisheries and Forests in the Context of National Food Security (VGGT). These Guidelines should not only be a check list for single cases of land grabs for agrofuel production, they should be used for the elaboration, assessment and revision of agrofuel policies.

2.3 The Maastricht Principles on Extraterritorial Obligations of States in the Area of Economic, Social and Cultural Rights.

2.4 In the Context of the EU, identified as one of the main actors in the fields of agrofuels, we would recommend to include the Treaty on the Functioning of the European Union (Art. 208 on the policy coherence for development). The social effects of the EU agrofuel policy in Africa (as the report highlighted in point 3 shows) contradict the objective of the EU development cooperation.

3 The report should further include documented violations of the right to food related to land conflicts linked to agrofuel production/ expansion. The zero draft is focussing on (global) price effects, while there is a need to address on an equal level human rights violations fuelled by agrofuel expansion – forced evictions, loss of access to land, criminalization of human rights defenders among them (see for example EuropAfrica, 2012, (Bio)fueling injustice? Europe’s responsibility to counter climate change without provoking land grabbing and compounding food insecurity in Africa, which includes case studies from Kenya, Mali and Senegal, pp. 37-48. Available at: http://www.europafrica.info/en/publications/biofueling-injustice.).

4 The above referred report of EuropAfrica is one of the most comprehensive reports on the role of the EU agrofuel policies and one of the most inclusive ones. It has been elaborated in a joint effort with African farmer organisations. The analysis in this report is based on a human rights framework and formulates detailed policy recommendations towards the EU and its member states. These recommendations could have relevance for the policy recommendations of the HLPE.

5 We would recommend identifying in a more precise way the responsibilities of different actors and related existing human rights obligations of states. Such a human rights based analysis would help identifying recommendations.

5.1 This would include a stronger human rights perspective on Biofuels and Land (Chapter 4), as access to land is a core element for the realization of the right to adequate food (references could be made to the General Comment Nr.12 of the UN Committee on Economic, Social and Cultural Rights (CESCR) and the VGGT, endorsed by the CFS).

5.2 Violations of the right to food should also be made explicit in the highly welcomed discussion on “mixed farming systems” as a key source of micro-nutrients. This should be done by including the human rights dimension of adequacy in the analysis.

6 Based on international human rights law, clear obligations of states to respect, protect and fulfil the human right to food including extraterritorial obligations should be identified. These legal dimensions should substantially inform the recommendations. 6.1 This should include recommendations to put in place legally binding measures to regulate financial and other actors active in agrofuel/ flexcrop investment with a view to preventing, and, if it takes place, remedying human rights abuses by those actors.

6.2 It also includes assessing and revising existing agrofuel policies to ensure that these policies do no harm to poor people and small scale food producers.

7 We welcome the clear emphasis of the water dimensions of agrofuel production. Linked the points mentioned above, we recommend that a right to water framework should inform this debate, as the right to water has been formally adopted by the United Nations General Assembly in 2010. The right to water has been interpreted by the CESCR in its General Comment 15.

8 We welcome the insights provided on the role of flexible crops in this framework. Nevertheless we believe that the HLPE report should include and strongly emphasize the following consideration about the linkages between global food security, the right to food and the evolving flex crops market: A national and global flex crop market bears the substantive danger that due to „market signals“ vast volumes of agricultural products will be shifted from the food market towards the fuels (energy) and fibre market in shortest time (and vice versa). In simpler words, food can disappear in seconds. This might lead to substantive price responses and – linked to the analysis as contained in chapter 3 – to massive violations of the right to food. This aspect is contained implicitly in some of the consideration of the zero draft, but should be highlighted in a more explicit way. We would thus strongly recommend including this real and substantive risk to the human right to food into the report.

9 Similar to the global debates, we see that the zero draft is based on a too narrow approach on ILUC, which is based mainly on the GHG debate. However, ILUC has also a substantive relevance for the access to land and water of rural communities. An example of global scale may illustrate this: In 2012 German newspapers reported that for the first time in 25 years, Germany had to import wheat again. One central reason for this has to be seen in the substantive boom in maize monocultures (for which the German neologism “Vermaisung” (i.e. “maizazation”) has been created) for bioenergy (mainly biogas). Germany’s need to import wheat from other countries is thus rising as a direct consequence of the national bioenergy development, and so are its “virtual land imports”.

10 The discussion of the EU RED and certification schemes (RSB etc.) should include a human rights based assessment. The absence of human rights criteria (not only linked to access to land and food prices, but also linked to lacking and/or intransparent accountability and remedy mechanisms to comply with human rights obligations) is not mentioned in the present draft. Overall, market-based certification schemes could be complementary to a regulatory framework but should not replace monitoring and accountability mechanisms based on states’ obligations under international human rights law. This should be pointed out clearly.

11 Based on the experience of CFS and the CSM, national and multilateral agrofuel policies should be assessed and monitored in a transparent and inclusive way. The experience from the CSM could inform such multi-stakeholder processes on national and international level. In particular, small scale food producers as the most affected by land grabs for agrofules / flex crops should have a substantive role in such monitoring activities.

12 Regarding principles for responsible agricultural investments, we would like to emphasize to not confuse the “Principles on Responsible Agricultural Investment in Farmland” – often referred to as PRAI – proposed by World Bank, FAO, IFAD and UNCTAD in 2009 with the on-going consultation process on responsible agricultural investments in an open-ended working group of the CFS. The CFS in it’s 36th session decided not to endorse the principles as suggested by the agencies named above, and has instead started an inclusive consultation process. The HLPE report should therefore distinguish more clearly these two things and underline in particular in recommendation no. 5 that the adhesion to principles of responsible agricultural investments should refer to the outcome of the on-going CFS process.

We stay at your disposal for any other bibliographic reference. Looking forward to the next draft for other comments.

Ensus Response to the consultation on FAO/HLPE’s V0 draft of the report Biofuels and Food Security

Ensus is pleased for the opportunity to respond to this consultation. However, Ensus has very serious and significant concerns about the analysis presented in this report. In particular we believe many of the data sources used and assumptions made, to be out of date, or simply incorrect. We also find many points being made not adequately supported by referenced data or by a clear explanation of procedures followed to draw the conclusions being offered.

In particular, we would offer a series of references which we believe provide more up to date and fuller analyses, of the effect of co-products on the contributions which biofuels can make. These co-products are a key part of the overall analysis, because they can fundamentally change the apparent performance of biofuels. The only contribution of co-products acknowledged in this study is to net off the feedstock used. However this ignores the point that co-products recover all the protein present in the feedstock, and can therefore displace other protein sources, with significant consequent environmental and economic benefit. This also results in reduced net land use, a credit component for ILUC effects, and benefits to the food sector.       

We would therefore urge the group to refer to the following peer reviewed publications:

• Biofuel Co-Products as Livestock Feed – Opportunities and Challenges; Chapter 2: An Outlook on EU biofuel production and its implications for the animal feed industry. FAO, 2012
• Impact of protein co-products on net land requirement for European biofuel production. Global Change Biology – Bioenergy (2009) 1(5): 346-359

We would be very happy to discuss these points in more detail with the Expert Panel at any time.

From: Timothy A. Wise, Policy Research Director, Global Development and Environment Institute, Tufts University, Medford, Mass.

Re: Comments on V0 draft of HLPE Biofuels Paper

Date: January 30, 2013

I congratulate the project team on a remarkable job taking on a complex and controversial topic and treating it with rigor and clarity. I find the strength of the paper, in the context of the CFS, is its comprehensive treatment of the topic – economic, social, and environmental aspects. Another is its clear emphasis on the food security implications, not just in the short term from higher prices but over the long term as well. This includes the very helpful presentation of the contribution to land-grabbing, a topic of great interest to the CFS. The modeling scenarios are well-presented and well-argued. The recommendations are justified by the text and data and make sense in terms of the problem at hand, with the CFS as one of the primary policy venues for discussion.

In response to the specific questions posed:

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

Yes, I find the framing of the issue generally quite good. The paper would benefit from a closer consideration of the policy conjuncture in key markets, particularly the U.S. and the EU. This includes the U.S.’s moves toward E-15 blends and the inflexibility of the RFS in the recent drought. The latter highlighted for many in the U.S. just how poorly structured the RFS is, written as it was before the 2007 price spikes ushered in the new era of high and volatile food prices. Discussing the needed flexibilities in more detail and the dangers of the moves toward E-15 in more detail would be very helpful. So too would a discussion of the perverse environmental implications of the looming regulatory arbitrage represented by the trade of corn ethanol from the U.S. for sugar ethanol from Brazil. For the EU, the policy considerations relate to the weaknesses in the newly announced (and misnamed) “cap” on crop-based biofuels, with the reduction from 10% to 5%. Any limit should apply to production and consumption and should adequately reflect impacts in the country of origin. The key transitional policy recommendation to emphasize is the move toward meaningful flexible mandates in which, by automatic trigger (price or stocks-to-use), mandates are relaxed, placing people clearly before cars and food before fuel.

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?

The presentation is strong and complete. It is important to detail the implications of ILUC not only for first but for second and third generation biofuels.

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?

The discussion is detailed an excellent, however there may be some ways in which we’ve lost the forest to focus on the trees. That is, there is now a clear body of evidence showing that biofuels contributed 20-40% of the food price increases seen in 2007-8, and there are subsequent studies that show continued contributions (see Babcock 2011, National Academy of Sciences, among many others). I am confident your team is aware of these studies. I think it is worthwhile to cite them in a paper of this sort, because the assertion is still considered controversial. The authors make a very interesting, compelling and original case that biofuel expansion represents the largest single factor contributing to high food prices since 2007. That case should be made in the context of a broader citing of the literature on the subject, and a lodging of your argument within that larger discussion and controversy. I characterize it as a consensus that biofuels have been a major contributor, and the debate is over how much. This needs to be well grounded in the literature.

The discussion of food price impacts on consumption could be made clearer. It is not always clear whether the authors are faulting the modelling assumptions or are indeed pointing to the modelling results as clear evidence that biofuels expansion causes significant reductions in consumption. This is a rich area to explore. I believe there are indeed errors in the modelling that can lead to erroneous results, but that does not mean that the main finding – that higher prices from biofuels effects causes consumption decreases – is incorrect.

US corn ethanol should get separate treatment because the evidence suggests it has the largest impact on prices. It is somewhat misleading to examine “grains” prices as a category for all countries, when the US is by far the largest export of corn and by far the largest producer of corn-based ethanol. It deserves its own treatment.

There is no need for biofuels and financial speculation to compete as causes of high and volatile food prices, and your presentation makes it seem that way. In fact, they complement one another perfectly. Biofuels expansions reduces the level of grain reserves. Scarcity, or perceived or feared scarcity, is the medium within which speculators best thrive. Speculators are more heavily invested in oil and other energy crops than in agricultural commodities, but biofuels ties those markets closely together. There is ample evidence that financial speculation has contributed significantly to the price spikes we have seen in recent years, particularly in 2007-8, while biofuels expansion has been, arguably, the main driver (with China’s growing soybean demand) of rising prices due to supply-demand imbalances.

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?

 I am not familiar with these examples, but I think it is indeed a rich area to explore.

One final comment. The discussion of gender implication is welcome and could be even further explored. Because the authors took on the full complexity of the biofuels issue it would behoove them to take on the gender implications in all their dimensions as well.

Please find attached my comments on your document. Thank you very much for giving the opportunity to respond to your investigation.

Kind Regards

Prof. Dr. Dr. h. c. P. Michael Schmitz

Giessen University

Germany

Please find attached the comments of the Renewable Fuels Association (U.S.).

In general, we believe the V0 draft needs substantial revision before it can be submitted for official peer review. Not only does the report fail to discuss potentially positive impacts of biofuels expansion on food security, but it also inappropriately expands the intended scope of the study, blatantly disregards input from the May 2012 consultation, fails to include a comprehensive literature review, and adopts highly questionable assumptions regarding animal feed co-products, crop yields and other factors.