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

Henrique Pacini UNCTAD, Switzerland

Good work on the V0 draft on the report on Biofuels and Food security.

Kindly follow some comments aiming at assisting you in the preparation of the second draft.  I also attach a publication which might be of interest on the theme of costs of biofuel certification and impacts on developing countries.

Kind regards,

Henrique Pacini

1.    Is the V0´s appreciation of the current policy conjuncture adequate, particularly its interpretation of the changing significance of mandates and targets?
•    Need for better modeling (or review of third-party modeling done) before making policy recommendations against biofuel mandates – while biofuels can compete with food production via land use, they are also energy carriers which have higher labor-density in their production (as compared to oil, see Goldenberg 2004).  Higher employment thus facilitates access to food, especially in rural areas. (see Figure 7)

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?
•    Correlations shall be explored not between food prices and biofuel demand , but instead between nutrition statistics and biofuel demand.  Food prices (as wisely mentioned in the draft report) are subject to too much speculation to serve as a basis for long-term recommendations on biofuel policies.

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?

p. 40 biofuels and ILUC section is rather biased – arguments on paragraph 3 such as “what happens biofuel producers use crops that farmers were growing anyway” ignore much of the demand additionality brought on by bioenergy crops.
P. 40 last paragraph: “… because we instead call for abandoning mandates and incentives to divert crops to biofuels in the first place” – While based on good argumentation and sources for this statement, the phrase proposes “shooting down” bioenergy without proposing alternatives to decarbonizes economies (and to make up for the reduced agricultural income, in case biofuels are not stimulated). A wiser path would be to call for a reflection on the way biofuels are “picked” by policy makers as the only way to achieve a higher share of renewables in transport.  Similarly to the EU RED directive from 2009, legal instruments could instead focus on “low-carbon energy” or overall sectoral emissions thresholds (as a mandate) instead of selecting biofuels as the technology to be deployed.   

p. 41 Section on Bioenergy: It is unrealistic to make comparisons between global energy demand and the small share of it that could be met by using large amounts of harvested biomass. This disconsiders other actions taken to cap energy demand (ee.g. efficiency, other renewables, urban planning, transport policy, smart logistics, etc). It should be made clear that proposals to use biofuels are often “complementary” to the usage of fossil fuels and other renewables – no country yet attempted or envisions full substitution of energy demand via biomass alone.

p. 51 Section 5.3: You may want to view information on certification costs explored by Pacini and Assuncao (2011).

Focusing on different usages is very important.  Electricity generation and better cooking prode lower-cost development multipliers based on biofuels.  See Gomez and Silveira (2010).

See the attachment:Pacini.pdf