Глобальный форум по продовольственной безопасности и питанию (Форум FSN)

Overall comments

• The current draft seems to have a quite negative bias towards biofuels, but in many places lacks sufficient scientific evidence to justify the conclusions drawn.
• IEA analysis suggests ((see: IEA Biofuel Roadmap, http://www.iea.org/publications/freepublications/publication/Biofuels_Roadmap.pdf) that even when the full range of efficiency measures and advanced technologies are indeed deployed rapidly, biofuels may still have an important role in decarbonising some transport sectors, particularly those related to long-haul transport, since there is a lack of other low-carbon technologies. Some of the conventional (1st generation) biofuels based on starch and vegetableoil based feedstocks will no doubt only play a limited role in achieving significant decarbonisation in the transport sector. There will therefore need to be a shift towards more advanced technologies using  a range of other feedstocks as input materials, notably residues and cellulosic based sources, if major carbon savings are to be made.
• The report should mention the important role of biofuels in the transport sector, and should discuss the impact of a scenario with large-scale deployment of advanced biofuels, compared to a scenario without biofuels (that the report seems to suggest), which would undoubtedly lead to higher transport sector emissions and thus a more rapidly advancing climate change, with possibly severe impact on agricultural production and therefore food security.

Specific comments

Executive Summary:

p.1, 1st para

• For instance, the first paragraph in the executive summary starts with a hypothetical, and very unrealistic scenario that assumes the use of the total global crop production for biofuel production.
• While one might argue such a theoretical exercise is justified in order to outline the maximum contribution conventional (1st generation) biofuels can make towards meeting our energy needs, it lacks some key aspects:
  • 1. The energy content of the biofuels is compared to the total primary energy supply worldwide. This comparison is not reasonable, as biofuels are principally used as transport fuel. The comparison should therefore be made with the world total transport energy demand (18.5% of total primary energy supply).
  • 2. No mention about co-products is made. However, most conventional biofuel crops have high protein feed as a co-product (soybean: 15% biofuel, 85% protein meal; corn: 30% biofuel, 30% DDGS), which draws a very incomplete picture.

p.1, 4th para; p. 14, 3 para

• There has never been a 10% biofuel mandate in the EU, only a target for 10% renewable energy in the transport sector by 2020. And more importantly, there has not been any decision in the EU to limit the contribution of conventional biofuels to 5% of total transport fuel demand in 2020. The only document that has yet been published is a European Commission draft legislation that includes, amongst others, the 5% cap as a proposal. The draft legislation is currently under review by Member States and will need to be formally adopted through the European Parliament, before it becomes legally binding.

p.2, 3-5th para

• The definition of 1st, 2nd, and 3rd generation biofuels is not clear, and does not cover some of the new technologies that convert, for instance sugar via microorganisms (other than algae) into fuels. The terms “fuel crops”, and “lignocellulose-technology”, are not defined and thus confusing. We suggest to use the IEA definition of conventional, and advanced biofuels (see: IEA Biofuel Roadmap, p. 8, http://www.iea.org/publications/freepublications/publication/Biofuels_Roadmap.pdf).

3. Biofuels, food prices, hunger & poverty

Overall comments:

• The chapter lacks the results of robust, scientific analysis on the key factors driving agricultural commodity prices. The source indicated is a 2011 report by the HELP, which again lacks a serious scientific analysis of the issue and instead refers to 3 studies that were published in 2008 (“After some initial debate, hardly anybody today contests the fact that biofuel production was a major factor in the recent food price increases (FAO 2008; Mitchell 2008; OECD 2008).”). However, at this time a proper analysis of the observed increase in food prices was not yet possible and more recent studies have been able to derive a much more balanced analysis on the impact of biofuels on food prices. This includes analysis from the World Bank (2010, Placing the 2006-08 commodity price boom into perspective), as well as analysis of OECD/FAO in their common Agricultural Outlook 2012 (relation between oil price and agricultural commodities: p. 41, Fig 1.17). These studies show that, other than claimed by the authors in the current report, the role of biofuels on commodity prices is limited. The key drivers are the price of oil, weather extremes, demand growth in emerging economies (higher share of meat in the diet), exchange rates and to some extent speculation.  The OECD Outlook, which is based on a robust modelling exercise, outlines in some detail the implications of higher oil prices, demand for meat and other factors on agricultural commodity prices, and shows the effect on different grain types, and should be consulted in detail to revise the conclusions drawn in chapter 3.
• The chapter seems to underestimate the impact of high prices and increased demand on crop production. Higher prices typically allow for production of crops on less productive land, and also lead to yield increases. On the other hand, without these price signals, farmers are not able to increase production due to economical reasons. The analysis that is missing in this paper is how large global crop production would be without biofuel production as a driving force in the market. The second step would then be to analyse the effect that rapid economic growth in emerging economies, combined with the high energy prices and extreme weather effects observed over the last decade, would have. These questions do deserve considerably more attention in the report, as they are important in order to address questions related to food security.

p.22, para 4

• The assumed 10% biofuel share worldwide in 2020 is more than unrealistic. Except for Brazil, the US and potentially the EU, no other country/region could reach such a share in the near future. The scenario drawn here should thus be revised to a more reasonable estimate, following for instance IEA analysis, which suggests that by 2020 4.5% of global transport fuel demand will be met by biofuels (IEA (2012), World Energy Outlook 2012, OECD/IEA, Paris).

p.22, last para

• The fact that there is a lack of scientific evidence supporting your conclusions should be flagged up front. It is questionable that such an important topic like the role of biofuels on food security is addressed by “rough” back of the envelop calculations, which the authors “believe” provide “reasonable evidence” to draw certain conclusions and policy recommendations.

p.23, para 3

• The report states: “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 statement is contradictory to any analysis on the economics of biofuel production. As is well known, feedstock prices account for up to 80% of total production costs of conventional biofuels, and profit margins are therefore strongly depending on feedstock prices. As shown in the figure below, the increase in corn prices during the summer of 2012 has led to a drop in US ethanol production as a result of lack of profitability. There is therefore no reason to believe that producers deliberately drove up grain prices, and the statement should therefore be revised.
•  

p. 27, 1st para

• The chosen data format does not seem to be suitable to analyse the actual impact of weather on yields, and production volumes of grains. A split in different grain types, ideally split by region would be more useful, since weather extremes are typically affecting specific regions, and crop types.

p.28

• It would be useful to not only present the share of biofuels in growth of grain production, but also as share of the total production.
• The conclusions drawn from the presented data are questionable and should be compared to analysis presented for instance in the FAO-OECD Agricultural Outlook (see above).

p.34, 3.4.3., 2nd para

• According to the FAO-OECD Agricultural Outlook 2012 (p.41), a 25% increase in oil price translates into a 14% increase in fertiliser prices. In addition costs for fuel for tractors, and other machinery along the supply chain increase. On the other hand, the energy input costs to an ethanol distillery also increase and reduce the profitability of ethanol production relative to the oil price. The conclusion drawn in the paper seems to underestimate these two strong relations between energy, and agricultural commodity prices, as well as the feedback effect of high energy prices on biofuel production costs.

Australian Contribution to the High Level Panel of Experts for Food Security and Nutrition (HLPE) report on Biofuels and food security

Overall comments

The draft HLPE report on ‘Biofuels and Food Security’ provides a useful overview and highlights well the range of key issues relating to biofuels and their implications for food security. It reads as a good summation of the state of play across countries and the scientific/economic perspectives currently influencing the biofuel agendas including research. It is largely a factual exposition which effectively illustrates the conflicting interactions between biofuels and food security in a world of finite land and energy resources.

The draft policy recommendations acknowledge the potential distortions that mandates, subsidies and tariffs can have on the market for biofuels. The report correctly reflects that the Australian Government has not introduced a national mandate, and that New South Wales is the only state to have one.

However, Australia considers that the analysis of the concept of food security in the draft paper is limited and as a result the recommendations are also limited. For example, the paper analyses food security arising from policy-based biofuels markets in terms of the FAO framework for assessing the determinants of food security – (i) access (i.e. food expenditure/income); (ii) availability (resources available for food production – mostly land and water); (iii) stability (access and availability guaranteed through time); and (iv) utilization (access to resources which enable food to be appropriated). However, the report does not analyse biofuels policy-induced food insecurity in the context of other factors impacting on food security, such as restrictive trade regimes, inappropriate price or output regulation, stockpile policies, dietary preferences, insecure land tenure, taxes on food production etc.  Such an analysis is required to determine the significance of biofuels policy-induced food insecurity in relation to these other factors influencing food insecurity.

Biofuel promotion also has economy-wide impacts aside from its direct impact on food production and price.  For example, replacing some of the liquid petroleum fuel market with biofuels leaves a larger amount of the hydrocarbon market available for the production of agricultural fertilizers, with consequent impacts on price and supply of the inputs to food production.  It would be useful to look at the economy-wide impacts of subsidies to biofuels to understand these effects.

A biofuels mandate may be a good policy for quickly developing a biofuels market. However, unless biofuels are able to compete in the fuels market in the medium to long-term absent the mandate, it is generally not good policy in the longer term. 

Research related comments

The Australian government submits the following general research related matters for the HLPE’s consideration:

• The interplay and synergies between energy security and food security are becoming more significant than ever though the impacts will vary across countries, with many food productivity advances being more energy intensive in nature particularly in developed countries but also in a range of developing countries.
• There is and will be a need for ongoing scientific research into biofuels to realise the latent efficiency potential of second and third generation biofuels in developing countries. In this case however, there seems to be large amounts of good research across countries without coordination and therefore considerable duplication of effort, including in developing countries that can ill afford the expenditures. Knowledge transfer mechanisms require increased attention to rectify this defect; with developed countries have a comparative advantage in most cases. It seems that a number of developing countries are engaging in R&D when other countries already have the basic know how which could be adapted in many cases with less expense. The use of jatropha is a case which is mentioned in this draft paper where countries have engaged in the research and production without real access to the scientific and economic information that should be readily available from public sector agencies in other countries; recognising that private sector researchers are understandably more restrictive with information for commercial reasons.
• While the information gaps are reducing with time, there is still a sense that biofuels are a panacea in some poorer countries where the costs of fossil fuels are increasingly prohibitive. This can lead to false expectations and misuse of resources driven partly by a lack of precise economic data and true reflections on the real opportunity costs of biofuels at country levels. There are very few if any genuine examples of biofuels which do not have an opportunity cost in terms of alternative land and water use for food crops. The exception is where by-products from food/feed crops can be utilised for biofuels or where biofuel crops are natural break crops, thereby reducing the marginal production costs and enabling producers including small holders to diversify the farm enterprise mix which is a basic income and risk management objective in many developing countries.
• It should be made clearer that the economics of biofuel cropping are volatile and short term horizons are less likely to have success. The variable costs and availabilities of fossil fuels have direct impacts on the viability of biofuels not only because of the comparative prices but also the fact that many biofuels require traditional energy sources at the processing stages which impacts on total production costs.
• The distortionary policy settings with subsidies and trade restraints in biofuel sectors of many developed countries is addressed in this paper, but we believe this should be emphasised further, given the negative impacts on food affordability in poorer countries over time.

We also submit the following specific comments:

• Appendix 1, page 65, the entry in the table for Australia requires amendment.  The column headed Mandate-Tools has the entry N/A, presumably meaning Not Applicable and it relates to mandates listed in Columns two and three. The Australian Government policy provides Ethanol Production Grants for producers of fuel ethanol to stimulate domestic production.  As well, it administers the Energy Grants (Cleaner Fuels) Scheme, which aims to provide grants for the manufacture or importation of biodiesel and renewable diesel, among other fuels, to offset any excise or customs duty and give a market advantage to these cleaner fuels. These grants apply throughout Australia and are not restricted to New South Wales. We suggest adding a separate column to capture such policies.
• The paper is inconsistent in its usage of metric and customary units of measurement (litres vs. gallons). There should be a single measurement system used throughout the reports, or alternatively dual reporting of figures presented in the paper.
  • For example, “x billion litres (x billion gallons)”

• The paper struggles to scale increases in demand for biofuels with rises in global food prices. This connection needs to be more clearly made to support positional statements in the report claiming the predominance of biofuels in food price increases.

Specific comments on the recommendations of the paper

Australia makes the following comments on the following recommendations of the report:

Recommendation One

Australia’s comments:

Australia recognises that global demand for biofuels is one of the many factors that may affect food security and food prices.

The government believes that inflexible mandates for biofuels are polices contrary to creating an open trading market. We would caution against major market intervention or regulation noting the potential for market distortion.

The Australian biofuels industry does not impact significantly on food prices in Australia due to the small scale of the industry and because of the emphasis on advanced biofuels which are derived from low cost, non-food crops, algae and agricultural wastes and would assist in mitigating competition between food and fuel.

Even if there was a substantial increase in demand for biofuels necessitating their production from traditional food crops, such as grains and sugar, it is unlikely to significantly affect food prices domestically as these commodities trade in global markets.

Recommendation Two

Australia’s comments:  The Australian Government has a policy interest in land use changes and recognises that this is a significant policy issue that requires careful consideration. The Australian Government employs a whole-of-government approach by working closely with states and territories on land use planning.  

In terms of foreign direct investment, Australia has well-established arrangements and regulatory frameworks to protect landholders, investors and communities.

Recommendation Three

Australia’s comments:

The recommendation is not clear as to whether it is referring to integrated land and water management, or the treatment of land and water as a single inseparable property right. The latter would be in conflict with Australia’s current water reform agenda under the National Water initiative, which guides the separation of land and water rights to allow water to be allocated to its highest value use. We propose inserting the word “management” after the phrase “land and water”.

Recommendation Four

Australia’s comments:  The Australian Government agrees with this recommendation.

Recommendation Five

Australia’s comments:  Australia questions the suggestion of a precondition to adhere to the broadly-owned RAI principles. See recommendation two comments regarding investment in Australia.  Investment–whether foreign or domestic–in the agricultural sector can bring significant benefits and opportunities for farmers. The Australian Government does not support an approach that would impose blanket bans or restrictions on foreign investment.

Recommendation Six

Australia’s comments:  Australia is participating in the development of an International Standards Organisation (ISO) Standard for Sustainability Criteria for Bioenergy which covers the economic, environmental and social aspects of sustainability.  The ISO standards involve some 30 countries of which many are from developing nations and experience many of the issues identified in the report.  The ISO standard seeks to address these issues whilst still allowing for the development of a biofuels industry in a sustainable manner.

Recommendation Seven

Australia’s comments: The Australian government is targeting investment in advanced biofuels which have the potential to build a sustainable new industry that could increase national fuel security, assist in reducing greenhouse gas emissions and stimulate regional development.

We are also working with the Biofuels Association of Australia and the ISO to develop internationally agreed sustainability criteria that can be applied to industry to ensure that support for biofuels does not compromise sustainable production practices and will provide greater impetus for move towards advanced biofuels. Voluntary certification schemes can be a useful mechanism for producers to demonstrate their environmental credentials to concerned consumers.

Most Australian exporters subscribe to either the International Sustainability and Carbon Certification Scheme (ISCC) or the Biomass Biofuel Sustainability Voluntary Scheme (2BSVS), which are formally recognised by the European Commission, to supply certified canola to the EU. However, exporters regard the cost of these schemes as an expensive and unnecessary impost, believing that the certification requirements should only be applied to countries with unsustainable production systems.

Recommendation Eight

Australia’s comments: Australia agrees that developing a biofuel’s policy based on the typologies of a country is beneficial. In December 2011, the Australian Government released the Strategic Framework for Alternative Transport Fuels. The Framework establishes a long term approach to a market led adoption of alternative transport fuels in Australia in the context of maintaining Australia’s transport fuel security while moving towards a lower carbon economy by 2030.

In regards to identifying trade-offs, the need for recommendation does not currently apply to Australia because, as previous mentioned, we believe our biofuel policies do not contribute to global food security concerns or have any significant impact of food prices because of the small scale of the Australian industry and because most Australian biofuel production is derived from waste products.

Recommendation Nine

Australia’s comments: The recommendation assumes the options are between using food crops or non-food crops for biofuel (ignoring for the moment the merits, or otherwise, of biofuel mandates etc).  However, there is some research, including in Australia, into the viability of using residues from crops grown for other purposes as the feedstock for biofuels.  This, ostensibly at least, solves the problem of displacing other land uses and should be addressed in the report.

Recommendation Ten

Australia’s comments: The Australia government is targeting investment in advanced biofuels which have the potential to build a significant and sustainable new industry that could increase national fuel security, assist in reducing greenhouse gas emissions and stimulate regional development. Therefore the recommendation to prioritise the development of non-biomass renewable fuels cannot be supported as Australia invests in the research, development, demonstration, deployment and commercialisation of various renewable energy and related technology innovations.

Recommendation Eleven

Australia’s comments:  Australia agrees with this recommendation.

Structure of the report

Some of the recommendations/conclusions at the beginning of the draft report do not seem to be fully reflected in the report itself.  In particular, the paragraphs/recommendations referring to national mandatory biofuel targets and subsidies that impact negatively on food prices: it would be helpful to show more clearly in the report the basis of the policy recommendations that have been reached.  We would also like to suggest that the proposed recommendations/conclusions come at the end of each of the chapters of the report rather than at the beginning of the report.

Concluding comments

The Australian Government thanks the HLPE for developing a zero draft of the ‘Biofuels and Food Security’ report and is happy to engage with the HLPE to provide comment on future drafts.

Firstly I would like to congratulate the team on the very interesting and thought-provoking zero-draft.

With reference to the CFS brief, my overall impression is that the draft provides a very useful analysis of the negative effects of biofuels on food security, but contains relatively little on positive impacts.

For example, our field research of biofuel operations in Mozambique and Tanzania found that households with paid employees in such operations were far more food secure, both from a calorie and micronutrient status, than other households in the same locality (and had shown the greatest improvement in food security since the operations were established)[1].

The other main impression drawn is the tendency toward generalizing about biofuels, particularly with regard to policy recommendations. We know that some biofuels are more efficient than others. Brazil has been producing cane-based ethanol since the 1970s without any major criticism of its impact on food security, and we know that cane is, for the most part[2], an efficient biofuel feedstock for reducing greenhouse gas emissions, as are a number of other feedstocks. Calling for an end to blending targets or mandates on these types of biofuel could be regarded as counterproductive to reducing global warming and food insecurity.

Furthermore, the cane-ethanol sector in Brazil has provided employment, helping to alleviate poverty and improve food security in many rural areas. This has been replicated in other countries, as illustrated by a study in Thailand showing how the ethanol sector there contributes far more jobs than the oil industry per unit of energy output, reducing the country’s oil import bill and helping to raise food productivity through spillover impacts[3]. Another recent report by the Stockholm Environment Institute suggests that cane ethanol production could be significantly increased in Malawi to help alleviate fuel shortages, due to the high import price of oil, and reduce deforestation.

Much criticism has, of course, been aimed at US maize-based ethanol due to its relatively low efficiency in reducing greenhouse gas emissions, and, perhaps more importantly, due to its influence on world food prices. As the US is the leading global exporter of maize, the US price generally denotes the world market value for maize, so the sharp increase in US ethanol demand is assumed to have had a significant impact on the rise in maize prices around the world.

However, much would also depend on how US supply increased to match ethanol demand, and the USDA suggests that a significant part of the rise in supply was due to additional plantings and multi-cropping by farmers and the use of higher yielding varieties[4], as well as a swing away from soybeans and other crops. This, together with the substantial amount of co-product outputs going back into the food and feed sector (both in the US and as exports to countries like China), would have dampened the price-raising impact of increased ethanol demand and limited the amount of maize diverted from animal feed and other markets. Indeed, it could be argued that these feedstuffs would not have been produced without the biofuel policy incentives, although it is impossible to tell how US maize supply and demand would have evolved without biofuels.

Then there is the point made by the FAO AgriMarket team, PANGEA and others that US maize price changes are not necessarily reflected in the markets where food insecurity prevails. And there is also the fact that (as stated in the draft) some rural farmers would benefit from rising prices as net sellers. Our research showed evidence of a multiplier effect where biofuel operations had been newly-established, introducing effective demand into a locality and encouraging increased food production by local farmers. Indeed, Swinnen and others rightly point out that NGOs and others lobbied against artificially depressed world cereal prices for many years, which acted as a disincentive for food production in many developing countries.

So, whilst the US maize ethanol policy may indeed have contributed to the rise in world maize prices, its impact on food security may not be as adverse as first appears. More importantly we need to find the right balance in the level and stability of food prices, which would provide an incentive for farmers in food insecure countries to raise productivity, whilst providing affordable food to consumers.

It is also important to acknowledge and support biofuels used for providing energy in rural and remote areas, as well as clean cooking stoves to reduce the many deaths caused by indoor smoke inhalation, and the hours spent in collecting fuelwood by so many people in the developing world, as well as reducing deforestation.

Regarding the policy recommendations, it would be important to ensure that beneficial biofuels and investments are encouraged, whilst those biofuels providing limited or negative benefits for GHG emissions, food security and other key socio-environmental issues (eg land and water rights), should be discouraged, including the removal of targets and other supportive policies.

So blending targets (and even mandates) may be suitable from a food security (and climate change) perspective in some circumstances, but this would largely depend on the biofuel feedstock and whether the country has sufficient land and labour resources to meet food and biofuel demand, as well as the way in which the biofuel is produced.

In this regard the development of multi-stakeholder sustainable certification schemes should continue to be encouraged and officially approved (and even mandated), such as that of the Roundtable on Sustainable Biofuels (RSB), which incorporates GHG emission and food security criteria. Only those biofuels and operations meeting environmental and social criteria should be authorized. Land and water rights must also be part of any certification system for allowable biofuels (also included in the RSB scheme), and any operations should adhere to the principles of responsible agricultural investment. 

In this way beneficial biofuels can be encouraged to promote food security and mitigate climate change.  

Stephen Thornhill

Consultant and Department of Food Business and Development, University College Cork, Ireland.

GENERAL COMMENTS FROM THE UNITED STATES

The “Biofuels and Food Security” Report (“the Report”) addresses an important topic: the impact of transportation biofuels production and use on food security. The Report provides useful insights into the state of global agricultural markets and land use practices, as well as environmental and social implications. We wish to provide the HLPE with the following input.

The Report inadequately considers the work of the FAO Bioenergy and Food Security Project and the Global Bioenergy Partnership on bioenergy and food security. The CFS mandated: “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 to be presented to the CFS.” However, the report only briefly cites work of the FAO Bioenergy and Food Security team. The work of GBEP is mentioned in a trivial way and is inaccurately listed under the section on certification schemes. The HLPE must restructure and rewrite this document in a manner that adequately takes into account the existing work of the FAO and GBEP on biofuels and food security.

The quality and impact of the Report will significantly benefit from considering previously published research, which assesses: the economic, social and environmental feasibility of biofuels; the impacts global and national biofuels policies; and the full range of impact(s) of biofuels production on food and nutrition security. In addition, more in-depth analyses of the industry dynamics and the forces leading to changes in local and global commodity markets would help in assessing the potential impact of biofuels on food security. Currently, the Report is written as a policy discussion piece, premised on the bias that nationally determined biofuels mandates - such as those in Brazil, the U.S. and EU - are overwhelmingly responsible for driving up the prices of food and thereby decreasing food security for the global poor. The report draws on a biased and unrepresentative sample of academic and (non-peer-reviewed) NGO publications to convince the reader of this outcome. The authors would be better served by summarizing the macro- and micro-economic literature, as opposed to using simplistic aggregate calculations of the possible impact of bioenergy on global energy supplies and on food security.

Future drafts of this paper should reflect the conclusions of FAO BEFS and GBEP, specifically that: bioenergy can improve energy access and food security for smallholder farmers in developing countries, when implemented in a rational and sustainable manner. In section 4.2.4 the paper mentions a balanced approach to bioenergy, citing “[a] recent UNU-IAS study on Biofuels in Africa by Gasparatos et al (2010) [that] develops a useful typology of biofuels at the level of individual production systems, demonstrating the importance of going beyond aggregate considerations.” The paper should be restructured to take into account the different roles that bioenergy and biofuels play in developed and developing countries, as well as the importance of looking seriously at distinct contexts when creating and implementing policies on the production and uses of bioenergy.

KEY PROBLEMS TO ADDRESS

1) It is insufficient for the HLPE to merely consider globally aggregated impacts of transportation biofuel production and use on food security. The HLPE must disaggregate the impacts of industrial transportation biofuels production from bioenergy for sustainable development. We recommend more rigorous calculations of the impact of biofuels that provide a thorough treatment and clearer evidence from available data, taking into account regional and national circumstances. Throughout the report, we also recommend using consistent, clear, and standardized definitions of food and nutrition security and bioenergy.

2) The HLPE must provide a more nuanced and thorough account of the causes of food and nutrition insecurity in developing countries, which draws upon a broader selection of the literature. Examples of causes include: post-harvest losses, due to a lack of energy access; insufficient infrastructure to transport domestically produced commodities and foods; national policies that inhibit development of the agricultural sector; and other limits on production, including barriers to trade. The HLPE should reference the work of FAO BEFS and the recent World Bank Report entitled “Africa Can Help Feed Africa: Removing barriers to regional trade in food staples”. (See below for full bibliographic details.)

CONSOLIDATED REFERENCES TO INCLUDE

For the HLPE to be responsive to its mandate, the report should discuss and cite this work:

• Dale VH and KL Kline. 2013. Issues in using landscape indicators to assess land changes. Ecological Indicators. http://dx.doi.org/10.1016/j.ecolind.2012.10.007
• Djomo, S. N.; Ceulemans, R. 2012. A comparative analysis of the carbon intensity of biofuels caused by land use changes. GCB Bioenergy 4: 392-407.
• Efroymson RA, VH Dale, KL Kline, AC McBride, JM Bielicki, RL Smith, ES Parish, PE Schweizer, DM Shaw. 2013. Environmental indicators of biofuel sustainability: What about context? Environmental Management 51(2) DOI 10.1007/s00267-012-9907-5.
• FAO. 2010. Bioenergy and Food Security: the BEFS analysis for Tanzania, by Maltsoglou, I. and Khwaja, Y., Environment and Natural Resources Working Paper No. 35, Rome.
• FAO. 2010. Bioenergy and Food Security: the BEFS analysis for Peru, Supporting the policy machinery in Peru, by Khwaja, Y., Environment and Natural Resources Working Paper No. 40, Rome.
• FAO. 2010. Bioenergy and Food Security: the BEFS analysis for Thailand, by Salvatore, M. and Damen, B., Environment and Natural Resources Working Paper No. 42, Rome.
• FAO 2010a. SOFI Technical Notes (methodology). The State of Food Insecurity in the World 2010 Technical notes. http://www.fao.org/publications/sofi/en/
• FAO 2010b. Food Outlook. Nov 2010. http://www.fao.org/giews/english/gfpm/index.htm
• FAO 2009a. Hunger in the Face of Crisis: Global Economic Slowdown Underscores Urgency of Addressing Long-Term Challenges. http://www.fao.org/economic/es-policybriefs/briefs-detail/en/?no_cache=1... Economic and Social Perspectives, Policy Brief #6. September 2009. This and other policy briefs at http://www.fao.org/economic/es-policybriefs
• FAO. 2009b. The State of Food Insecurity in the World. http://www.fao.org/publications/sofi
• FAO-IIASA (2007). “Mapping biophysical factors that influence agricultural production and rural vulnerability.” Food and Agriculture Organization and International Institute for Applied Systems Analysis, Rome 2007.
• Fisher, M. J., I. M. Rao, M. A. Ayarza, C. E. Lascano, J. I. Sanz, R. J. Thomas, and R R. Vera 1994. Carbon storage by introduced deep-rooted grasses in the South-American savannas. Nature 371:236-238.
• Global Bioenergy Partnership. 2011. The Global Bioenergy Partnership Sustainability Indicators for Bioenergy, First Edition, Rome.
• Heaton E., Voigt T., Long S.P., A quantitative review comparing the yields of two candidate C4 perennial biomass crops in relation to nitrogen, temperature and water. Biomass and Bioenergy 27:21-30 (2004)
• Heaton E.A., Dhleman F.G. and Long S.P., Meeting US biofuel goals with less land: the potential of Miscanthus. Global Change Biology 14: 2000-2014 (2008)
• Kim, Hyungtae, Seungdo Kim, and Bruce E. Dale. "Biofuels, land use change, and greenhouse gas emissions: some unexplored variables." Environmental Science & Technology 43, no. 3 (2009): 961-967.
• Kline KL, VH Dale, R Lee, and P. Leiby. 2009. In Defense of Biofuels, Done Right. Issues in Science and Technology 25(3): 75-84
• Kwon, H.; Wander, M.; Mueller, S.; Dunn, J. B. 2013. Modeling state-level soil carbon emission factors under various scenarios for direct land use change associated with United States biofuel feedstock production. Biomass and Bioenergy, under review.
• Mann, L., and V. Tolbert. 2000. Soil sustainability in renewable biomass plantings. Ambio 29:492-498.
• Mueller, S.; Dunn, J. B.; Wang, M. 2012. Carbon Change Calculator for Land Use Change from Biofuels Production (CCLUB) Users’ Manual and Technical Documentation. ANL/ESD/12-5. May 2012.
• Mueller, S.; Copenhaver, K.; Begert, D. 2012. An assessment of available lands for biofuels production in the United States using United States Department of Agriculture (USDA) cropland data layers. Journal of Agricultural Extension and Rural Development, 4: 465-470.
• National Research Council. 2012. Sustainable Development of Algal Biofuels in the United States. National Academies Press, Washington, D.C.
• National Research Council. 2011. Renewable Fuel Standard: Potential Economic and Environmental Effects of U.S. Biofuel Policy. National Academy Press, Washington, D.C.
• Oladosu, Gbadebo, Keith Kline, Rocio Uria‐Martinez, and Laurence Eaton. "Sources of corn for ethanol production in the United States: a decomposition analysis of the empirical data." Biofuels, Bioproducts and Biorefining 5, no. 6 (2011): 640-653.
• Oladosu, Gbadebo, Keith Kline, Paul Leiby, Rocio Uria-Martinez, Maggie Davis, Mark Downing, and Laurence Eaton. "Global economic effects of US biofuel policy and the potential contribution from advanced biofuels." Biofuels 3, no. 6 (2012): 703-723.
• Oxfam 2010. Hunger in the Sahel: A permanent emergency? Oxfam Briefing Note (Etienne du Vachat; Eric Hazard) 15 December 2010.
• http://www.oxfam.org.uk/resources/policy/conflict_disasters/downloads/bn... Accessed January 24, 2011.
• Parish ES, KL Kline, VH Dale, RA Efroymson, AC McBride, T Johnson, MR Hilliard, JM Bielicki. 2013. A multi-scale comparison of environmental effects from gasoline and ethanol production. Environmental Management 51(2) DOI: 10.1007/s00267-012-9983-6
• Pate, R., G. Klise, and B. Wu. 2011. Resource demand implications for U.S. algae biofuels production scale-up. Applied Energy 88(10):3377-3388.
• Tolbert, V. R., D. E. Todd Jr., L. K. Mann, C. M. Jawdy, D. A. Mays, R. Malik, W. Bandaranayake, A. Houston, D. Tyler, and D. E. Pettry. 2002. Changes in soil quality and below-ground carbon storage with conversion of traditional agricultural crop lands to bioenergy crop production. Environmental Pollution 116: S97-S106.
• Wallington, T. J.; Anderson, J. E.; Mueller, S. A.; Kolinski Morris, E.; Winkler, S. L.; Ginder, J. M.; Nielsen, O. J. 2012. Corn ethanol production, food exports, and indirect land use change. Environmental Science and Technology, 46: 6379 – 6384.
• M. Wang, J. Han, J. Dunn, H. Cai, and A. Elgowainy, 2012, “Well-to-Wheels Energy Use and Greenhouse Gas Emissions of Ethanol from Corn, Sugarcane, Corn Stover, Switchgrass, and Miscanthus,” Environmental Research Letter, 7 (2012) 045905 (13pp).
• Wang, M., J. Han, Z. Haq, W. Tyner, M. Wu, and A. Elgowainy, 2011, “Energy and Greenhouse Gas Emission Effects of Corn and Cellulosic Ethanol with Technology Improvements and Land Use Changes,” Biomass and Bioenergy 35 (2011): 1885-1896.
• World Bank. 2012. Africa Can Help Feed Africa: Removing barriers to regional trade in food staples, Poverty Reduction and Economic Management - Africa, Washington, DC.

Together, these publications make the following essential points when considering the relationship between bioenergy and food security. Specifically:

1) The positive or negative impacts of bioenergy on food security raise complex issues, which need to be considered in country-specific, regional, and international contexts.

2) The production and uses of bioenergy have benefits and challenges. Policy tools - such as the BEFS Analytical Framework and the GBEP indicators - can assist countries in optimizing the benefits and minimizing the challenges, including challenges to food security.

3) Food insecurity is driven in large part by a lack of energy access. Bioenergy production and use can improve food security by providing energy for food production, food storage (drying and cold storage), and food transportation.

En el caso del Perú cuenta con las suficientes condiciones necesarias para producir etanol de manera rentable, debido a que la caña de azúcar (insumo) cuenta una mayor productividad que la del promedio del resto del mundo. Estas ventajas son transmitidas al costo (el 60% depende del insumo), el cual es menor por litro producido; es decir, se cuenta con una ventaja comparativa en la producción de etanol.

En este sentido, la costa norte es la región que muestra las mejores oportunidades para producir etanol, no solo por tener amplias extensiones de tierras agrícolas, las cuales pueden ser sometidas a regímenes de riego, sino también por la puesta de nuevos y ambiciosos proyectos que han hecho aumentar la rentabilidad en sus tierras (más de una cosecha al año) atrayendo nuevas inversiones a una industria como la cañera que comienza a tener excesos de producción que pueden ser dirigidos a la producción de los biocombustibles.

La alta volatilidad del precio del petróleo, el daño climático causado por su uso y el proceso de reemplazo de las matrices energéticas en EE.UU. y la Unión Europea aseguran una demanda externa creciente y sostenida para el futuro. Por otro lado, la demanda interna está siendo fomentada por la ley de promoción de los biocombustibles. Es así que la demanda de biocombustibles a nivel mundial estaría asegurada de cumplirse este panorama.

En nuestro caso, en la region Piura en Peru, la problematica del incremento de la tasa de siembra de caña de azucar para iocombustible ha sido instalada en sectores donde habia bosque seco, no solo se esta atentanto cntra la biodiversidad sino tambien con el impacto ambiental que se esta generando en los sectores aledaños por la contaminacion atmosferica. Sin embargo, el Estado, ya sea a través de los ministerios o de los gobiernos regionales, deberá prepararse para afrontar las posibles dificultades en su desarrollo, así como para verse favorecido con sus logros. El papel del Estado es primordial para brindar las condiciones necesarias para la expansión de esta industria emergente, es decir, fomentar a la inversión, un marco legal favorable y una mayor apertura de nuestros mercados (TLC).

 Dra. Ninell Dedios Mimbela

CIDMA-Perú

Centro para la Investigacion Desarrollo y Defensa del Ambiente

We welcome the opportunity to comment on this report on this important subject. We also welcome further studies and analysis in this subject area.

However, overall, we have serious concerns regarding the evidence base and analysis supporting the assertions and conclusions of this report, given the stated aim: 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”.

• Many of the sections start with assertions that are not backed up by the evidence presented within them, which consists of thin and selective analysis. The report itself acknowledges that the policy proposals have been presented without supporting evidence, and invites stakeholders to provide the evidence to support them.
• The literature analysis is also thin with many more up to date reports and analyses missing.
• Finally, many of the headline figures in the report, such as the percentages of crop supply needed to provide a percentage of transport demand through biofuels, are calculated in an unclear way, with the underlying assumptions sparsely described in the footnotes. Given that these figures are likely to receive considerable citation and scrutiny, they should be set out in full in annexes, with assumptions and references for each step. It is not possible for consultees to review them in their current state. From the information available, it also seems evident that the authors have made inappropriate comparisons: such as taking today’s production as a proportion of 2020 or 2050 demands

In terms of the content of the report itself, we would like to highlight a few areas where we believe much greater scrutiny and analysis are needed, or where other evidence is missing or needs to be taken into consideration (this list is just indicative and not meant to be exhaustive);

• We have serious concerns over much of Chapter 3, on the influence of biofuels on food prices. For example, the report asserts that the price of gasoline sets the price of ethanol, and that this in turn has driven up grain prices in the US. In reality, the current corn ethanol price in the US is set by the corn price, because of excess capacity in the sector.
• The report significantly underestimates the potential for second generation biofuels. It focuses on ‘current’ costs and technology development status, based on references from old data (2008 and earlier). It is important to recognise that there are now a number of second generation plants in construction and commissioning, with production starting up over the next few years, and cost reduction expected. The report also does not cover recent evidence on the greenhouse gas balance of biofuels, which shows that the variation between routes is predominantly due to different supply chains and practices rather than inherent uncertainty. The potential for biofuels from residues and wastes is presented as small, on the grounds of logistics and environmental impacts, even though recent detailed analyses show benefits even when taking these factors into account.
• Chapter 4 on land does not cover many vital studies in reviewing the evidence on land availability for food and biofuels. Detailed reviews of this topic have been done recently by the IPCC, and by the UK Energy Research Centre, using a systematic review approach and these sources should be looked at for this report. The UK Energy Research Centre found that many studies give a sustainable potential of at least 100 exajoules (EJ) of biomass in 2050, or a fifth of current global primary energy demand, after food demands are supplied.  An expert review for the Intergovernmental Panel on Climate Change (IPCC) concluded that the sustainable potential could be even higher, at 100 to 300 EJ.
• The report’s coverage of land grabbing restates data claiming that up to 2/3 of land grabbing is linked to biofuels. From analysis of the reports and data from the ILC and the Land Matrix project, we are seriously concerned that there is very little evidence to support such a figure.  The planned crops for many of these deals could be used to produce biofuels, but there is little evidence given that they are actually intended for biofuels.

We would be happy to meet with the HLPE Steering Group and Project Team to talk through our concerns on the report, and to provide further details of evidence to help inform the next version.

Dear Sir/Madam,

Herewith, please find enclosed Novozymes comments to the HLPE draft (V0) report on “Biofuels and Food Security” (word and pdf).

If you are not familiar with Novozymes, we are a Danish industrial biotechnology company.  One of our businesses includes enzymes for the production of starch-based and cellulosic ethanol.

Please do not hesitate to contact us should you need further information or have any question.

We would be grateful if you could keep us updated of the future drafts of the report as well as related activities.

Many thanks in advance and best regards,

Nour

Nour Amrani

Public Affairs and PR Manager

Dear HLPE Secretariat,

Please find attached NR’s comments received from both the Climate Change, Energy and Tenure team (NRC) and the Land and Water Division (NRL) on V0 of the HLPE report on Biofuels and Food Security.

You have already received the NRC’s contribution from Ms Yao, Director-NRC earlier today.

Regards,

Alexander Müller,  ADG/NR

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

It is accurate as it relates to: i) shifting demand and investment origins, ii) calling for global regulation and/or strengthening national regulations in LDCs and iii) the fact that biofuel investments, and donor support have opened more space for other investments in commercial agriculture having worsened the magnitude of  land grabs, food insecurity etc. 

However, the draft could go further to accurately reflect the new European Commission (EC) proposal, which includes a 5% cap on consumption, limiting the amount of food-based biofuels that can be reported as renewable energies. The report should update its interpretation of the EC proposal and recommend that caps be adopted for production and consumption, not only reporting.

In addition, the draft could more clearly present those policies which have other goals (e.g. renewable energy/climate, energy security, agriculture) but which incentivise biofuels production and/or consumption. It should recommend that all such policies be modified. We would support the adoption of enforceable caps on production and consumption at the CFS level, that are gradually moving towards 0% land based biofuels.

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?

1) It could further detail effects on social fabric, gender relations, health, extension support, agricultural development dynamics and the political economy at large;

2) The ILUC issue could be more clearly framed. The report states that in calling for the elimination of mandates and incentives there is no need to do anything with further ILUC. However, ILUC is still a potential issue when it comes to second generation biofuels.  It should make reference to the scientific evidence on ILUC such as the studies commissioned and used also by the EC (e.g. IFPRI Report);

3) The issue of land availability is discussed on the basis of macro data and mapping ("445 million hectares available”, “80% of sub-Saharan savannah available " FAO 2009...), which do not take into account the actual use of land. These can only be determined through precise satellite and field investigation;

4) In section 4.2.3, the report could be even more explicit about the need for fertile agricultural land to grow jatropha on a commercial scale. We would like to see a clearer analysis of the carbon effects of jatropha plantations[1];

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?

The VO is certainly one of the more interesting analyses out there and is very clear in linking biofuel demand with the surge in food prices at international level.  It is also useful in describing the “qualitative effects” in relation to the impact on hunger. However, ActionAid would propose further discussions along these lines:

1) The low level of attention given to the effects of national level policies that promote biofuels (targets, subsidies); to the elaboration of biofuel feedstock sustainability criteria in combination with support to national biofuel policies and strategies, and even land legislation to facilitate land investments (FDI and local) and how this influences national agricultural development policies, institutions and the political economy at large[2];

2) Biofuels promotion by international players which often conflicts with national energy security policies;

3) Related to this, the biofuels rush which also contributed to reduced investments in demand-driven extension to rural communities vital to the transformation of livelihoods of smallholder farmers and the needs of rural women;

4) Multiple responsibilities in terms of investment agencies, joint ventures, outsourcing of management and frequent take-overs. These lead to an opaque and confusing patchwork which threatens accountabilities and liabilities, with communities ultimately losing out. The picture gets even more blurred by the involvement of local actors like national petrol companies engaged in ventures for biofuel promotion serving national demands as well as those from non-EU countries. This means that subsidies/favorable financing options by EU countries or EU-based actors do not only and fully benefit RED targets;

5) The huge impact of land speculation (rent-seeking) and the interests of national political economic elites, often partnering with foreign investors should not be underestimated;

6) The effects of labour market transformations and the migration of men (to estates or other centers of employment, urban/mining areas, etc.) have resulted in the marginalization of women and children and affected their food security. In turn, increased health & nutrition risks due to the separation of families (e.g. HIV-AIDS), work in swampy environments/ irrigated areas (leading to malaria, water-borne diseases) should not be underestimated.  Likewise vulnerable female-headed households are at risk due to the feminization of the HIV-AIDS crisis. Issues of seasonal labour and violation of labour laws at estates are also factors to be dealt with;

7) There is a need to further research the failure to live up to promises in terms of social (employment, food security, etc.) and environmental claims being made and due diligence so as to verify those claims and enforce responsibilities;   

8) Ex-ante feasibility studies on biofuel investments are insufficient in terms of assessing potential negative environmental and social impacts and rarely consider cost-benefits and opportunity costs from the perspective of rural communities, in particular from the perspective of women.  The report should examine this issue and recommend that all studies should analyse these aspects;

9) Access to nutritious food by the most vulnerable segments of communities, in particular women and children, should feature more prominently in food security strategies that often merely emphasize national or regional food sovereignty;

10) Likewise the feminization of biofuels-related land grabbing and food security could be further deepened;

11) The report focuses on world prices. It would be useful to examine changes to food prices at national and local levels, when biofuels production and consumption are introduced. For example, developing a 50,000 or 100,000 HA sugar cane or palm oil plantation including transformation unit and export infrastructure will necessarily have an impact on food availability and prices.

12) The issue of food security and its four dimensions should be further studied[3];

13) The issue of certification schemes should also be studied further: they are not "virtually regulatory" not even with the RED. The latter allows the EU to adopt Economic Partnership Agreements (EPAs) that guarantee certification for the entire production of the exporting country, without including any penalty or exclusion mechanism for non-compliance nor permitting thorough control of production[4]

14) Somewhat missing is the issue of chemical fertilizers, and other chemical inputs impacts of large scale biofuels, also the lack of enviromental and natural resources impacts since they represent risks to food security and livelihoods.

15) On the point that "basic criteria such as land availability and per capita income can aid in the identification of the type of policies which would make sense in a given country," we feel that there are other aspects to be considered, including culture, natural resources and so on. The way Brazil is presented, for example, as a country with abundant land is over simplified. This does not guarantee that policies will be well implemented. At local and regional levels in Brazil, there are many different problems with large scale biofuels expansion.

With regard to the impact of jatropha specifically:

1) The failure of (partly subsidized) jatropha can – to a large extent - be explained by a lack of experience of estate managers with the crop and working environment in rural Africa. It is also related to unrealistic assumptions made about managing contract farming and outgrowers with the involvement of rural communities, as well as challenges faced in engagements with local leaders;

2) There are references to land and water grabbing for Jatropha. This factor may be much stronger for sugar cane;

3) The magnitude of Jatropha failures supported with public aid money may be sufficient reason to call for a ban based on purely economic rationale, not to mention negative social and environmental  impacts;

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?

ActionAid does not have such examples, but would like to see more evidence of them and how they are working in practice. We do know that some national policies e.g. that of Mozambique, take this direction on paper. However the practice is often very different[5] and local and international stakeholders are taking advantage of a lack of enforcement, which may be due to lacking capacity or a real political will to enforce. Production for the local/national market (import substitution fossil fuels), which is restricted to areas not suitable for or in competition with food production is not happening. We are not seeing positive impacts on smallholder farming/employment generation or food security. The reality is quite the opposite.

Overall, we would support these models, as long as it is recalled that policies such as the EU’s 10% renewable energy target (88% of which is to be filled by first generation biofuels by 2020) does not support such models. These policies rather encourage large-scale export based models. Secondly, it is important that the definition of ‘marginal lands’ is not constructed in such a way that land already being used by marginalised groups are not removed from their land to produce biofuels.

Overall the VO could be improved by discussing the kinds of models that will make a bioenergy policy work well for development. It is necessary to further examine:

1. Business models
2. The matrix (p.48)
3. Further analysis on sustainable criteria[6]
4. The social dimension

Finally, there is an overall problem associated with a lack of formal research on the gender, food security and political economy aspects of biofuels.  The lack of research as well as due diligence around compliance with social and environmental standards, increased vulnerability/ food insecurity and malnutrition areas amounts to evidence in itself.

ENDS

Contact Person: Laura Sullivan

Dear HLPE Secretariat,

Thank you for this opportunity to comment on the HLPE draft. We would like to emphasize the part of recommendation 7: "The conclusion here and the corresponding policy proposals point to the need for all land investments and all agricultural production to be socially and environmentally sustainable." - Neste Oil fully supports the recommendation and welcomes all the actions needed to develop and implement the legislative instruments or international agreements for this purpose. Further comments, please see the attached document.

With kind regards,

Pekka Tuovinen

Director, Sustainability and Supplier Compliance

Neste Oil Corporation