Memorandum submitted by Global Forest
Coalition, Global Justice Ecology Project
First, we believe strongly that any questions
regarding the impacts and sustainability of the production of
biomass for vehicles should be completely resolved prior to any
mandatory targets for biofuel. Mounting evidence indicates that
there are numerous negative impacts and uncertainties regarding
biofuel production. Targets act as an incentive to encourage investment,
research and development, which is already occurring at so rapid
a pace that thorough evaluation is not possible. It is clear that
large scale industrial agriculture is extremely costly in terms
of impacts on land use, soils, water resources, people and biodiversity,
and results in more use of toxic pesticides, herbicides and nitrogen
fertilizers. Many of these factors are neglected from consideration
of the overall impacts of biofuels on climate, even though they
may largely negate any of the supposed benefits.
Even where some impacts are taken into consideration,
it is virtually impossible to account for the multitude of indirect
impacts. For example, when agricultural lands are usurped for
biofuel crop production, food and livestock production may move
into adjacent forest frontier, causing more deforestation. Or,
when corn prices rise in the US because of demand for ethanol
production and fewer US farmers plant soy, the price of soy on
the world market rises, causing expansion of monoculture soy production
in Latin America. This accelerates deforestation, the final step
in a complex indirect relationship between corn and deforestation.
As another example, when (and if) cellulosic ethanol becomes viable,
it is expected that production of trees for fuel will displace
production for pulp into different regions and result in further
displacement of indigenous peoples. Such indirect and "leakage"
effects are more complex, more numerous, more difficult to monitor
and predict in the context of a globalized economy and cannot
be adequately managed with sustainability criteria.
In countries like Brazil that have a long-standing
experience with biofuel production, the current rapid expansion
of ethanol production has raised deep concerns amongst Brazilian
NGOs and farmer's movements.
Efforts, to develop viable sustainability criteria
for soy production (RTRS) and palm oil production (RSPO) have
been soundly rejected as ineffective by people in producing countries.
Such criteria have resulted in purely cosmetic treatments that
do not actually result in true sustainability. There are a number
of reasons why these schemes fail. One is the difficulty of addressing
indirect "leakage" impacts. Also, in many regions, enforcement
of criteria is impossible, conflicts of interest between producing
and consuming nations are often left unresolved, and stakeholder
participation is imbalanced, excluding input from many of those
who are most directly impacted. Given that these previous attempts
at developing sustainability criteria have proven so inadequate,
it is not prudent to assume this approach will be feasible and
effective for biofuel production.
The introduction of a mandatory target at this
stage causes a focus of attention on fulfilling the target goal
itself rather than the underlying intention of the goal, to reduce
green house gas emissions. A mandated transition towards biofuels
must be assessed within a broader context of possible means for
reducing greenhouse gas emissions, including reducing consumption,
improving efficiency, halting deforestation and peatland degradation.
If any targets are to be mandated, or incentives offered, these
should first be for more benign energy sources, such as wind and
solar energy, and more sustainable forms of transport like public
transport and cycling.
Finally, we want to point out that NGOs and
social movements from all over the world have called for an immediate
moratorium on all forms of support for the import and export of
biofuels. Touted as an economic opportunity for rural farmers,
in reality they are creating conflicts over land and a dire threat
to food sovereignty in many countries.
1 October 2007
|
