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

Federal Government of Germany ,
FSN Forum
  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