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
Elisa Calcaterra