ACTIONAID RESPONSE TO HLPE VO DRAFT REPORT: BIOFUELS AND FOOD SECURITY
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.
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?
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 plantations1;
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 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 large2;
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;
1
See this report for evidence: http://www.actionaid.org/eu/publications/sustainability-criteria-
review-jatropha-biofuels-dakatcha-woodland-kenya
2
This has been the case e.g. in Mozambique, where among others the EU, Italy and the
Netherlands have provided support to fast-tracking biofuel policy and strategy development,
elaboration of a biofuels sustainability framework, etc. The national biofuels policy and
strategy emphasise that biofuels should be produced to substitute imports of fossil fuels into
Mozambique. However this conflicts with the exports to EU that are not explicitly mentioned
as a national priority in the strategy, but are part of the reality on the ground. Schut et al.,
(2010) provide full evidence that biofuels investments in Mozambique largely took place in
populated areas usually characterized by fertile soils and availability of irrigation water. This
conflicts with the pathway described in the national biofuels policy & strategy and suggests
that there will be competition between commercial farming and smallholder farming and
between the production of food crops and cash crops, etc.
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 studied3;
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 production4
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.
See comment on availability, we could add the issue of agriculture workers’ wages, which
do not necessarily permit to buy enough food
4
Only a very small percentage of the production is controlled
3
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 different5 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.
5
(Schut et al., 2010)
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.
2.
3.
4.
Business models
The matrix (p.48)
Further analysis on sustainable criteria6
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, laura.sullivan@actionaid.org
6
It is not certain the certification schemes of the EU, for example, are really able to work