Response to
UK Department for Transport Consultation
On the Draft
Renewable Transport Fuel Obligation

May 2007
Africa Biodiversity Network, Kenya
Melca Mahiber, Ethiopia
Envirocare, Tanzania
Climate and Development Initiatives, Uganda
Nature Tropicale, Benin

An African Response to UK Biofuels Targets

This document is a response from African Non-Governmental
Organisations (NGOs). Although we have not been invited to respond
to the consultation, we nonetheless feel we are significant
stakeholders in the outcomes of the UK Government's Renewable
Transport Fuel Obligation (RTFO).

Our organisations are concerned with issues of agriculture,
biodiversity, food security, livelihoods, climate change, traditional
cultures and indigenous rights in Africa. We feel that the targets
of the RTFO are likely to impact on those whose concerns we
represent, namely those of rural and indigenous communities in
Africa – those communities who are typically unable to participate in
these distant discussions about subjects that will dramatically
affect their lives.

We therefore thank the UK Department for Transport, and other
stakeholders, for considering our position, and treating our comments
with the consideration and seriousness that we believe they deserve.

African Biofuels to Meet UK Targets

We have serious concerns about the implications of the UK's RTFO
Biofuels Targets. Our concerns are that by increasing biofuel
targets for the UK (where there is limited available land), these
targets will need to be met by imports. These imported biofuels are
likely to come, in large part, from Africa.

In order to meet the biofuel needs of the UK (as well as the rest of
the EU), the conversion of land to provide the scale of biofuel crops
required, is likely to significantly influence land use policies, and
to have negative socio-economic and environmental impacts.

Numerous biofuel initiatives are already expanding and proliferating
in African countries, suggesting that this is just the beginning of a
massive trend. Recent biofuel developments include those in South
Africa, Zambia, Uganda, Tanzania, Benin, Ethiopia, Kenya and Ghana,
among other countries.

South Africa

There has been no discussion within these countries about the likely
impact on rural communities, or on food security. The exception to
this is South Africa, where a Biofuels Strategy provoked a strong
response from farmers organisations, rural communities and NGOs,
objecting to "land grabs" of communal and tribal land, where rural
farming communities have been forced to sign over their land for a
pittance for industrial plantations of oilseed rape, maize and soya.
(Please see annexe document "Rural communities express dismay: `Land
Grabs fuelled by Biofuels Strategy'".)

Uganda

A process to degazette Uganda's natural forest land, Mabira Forest
Reserve, for the expansion of sugar cane plantations has sparked off
public riots that have resulted in several deaths. These
developments come in part from sugar companies' strategies to
diversify into the lucrative bioethanol market.

Mabira Forest is the watershed for two rivers that contribute to the
Nile, it protects Lake Victoria, and is an important absorber of
pollution in a major industrial area. The forest represents millions
of tonnes of carbon dioxide, and according to Uganda's National
Forest Authority (NFA), the plan to log Mabira threatens 312 species
of trees, 287 species of birds and 199 species of butterflies. Nine
species found only in Mabira and nearby forests risk going extinct.

World Bank experts warn that cutting the forest will lower the water
levels in the Upper Nile and Lake Victoria. This will have dramatic
consequences for livelihoods, agriculture, rainfall, and electricity
production. The likely soil erosion, droughts, floods and landslides
from the cutting down of the forest, cannot yet be quantified in
economic terms, but will be yet more burden for the people and
economy of Uganda to carry.

Further biofuels developments on the Kalangala Islands in Uganda have
led to large areas of tropical forest being cut down to make way for
palm oil plantations for biodiesel.

Benin

In Benin, government plans are underway to develop large areas of
peatland for palm oil plantations. According to Wetlands
International, the destruction and burning of the South East Asian
Peatlands in Indonesia and Malaysia for palm oil plantations, is
responsible for 8% of global CO2 emissions.

The Benin government plans to scale up from household and small-scale
production, to large-scale biofuels production from cotton seed, cane
sugar, manioc, sorghum, maize, soya and ground nut, in order to enter
the international biofuels market. However, the government and
actors have failed to take into account any considerations of the
socio-economic and environmental impacts of this strategy, for
example how farmers are to accommodate increased competition for
their land and food crops.

Socio-economic and environmental considerations

Large-scale biofuels developments elsewhere in the world also hold
valuable lessons: The destruction of the Brazilian Amazon and
Pantanal for soya and sugar cane plantations; the appalling
conditions, sometimes comparable to slavery, of many sugar cane
plantations in Brazil; the destruction of the Indonesian rainforests
for palm oil; the rising price of grain in Mexico due to its
consumption for US ethanol, leading to hunger and riots. We believe
we have every reason to expect similar developments in Africa.

The issue of climate change is serious, and we in Africa know this
more than most. We agree that action by industry and transport in
the UK is necessary. However, we urge you to consider the socio-
economic and environmental impacts that a large-scale promotion of
biofuels will have on Africa.

The Stern Report states that 25% of global CO2 emissions come from
deforestation. Therefore any biofuels projects that accelerate
deforestation must not be allowed to pass themselves off as
environmental solutions to climate change. Forests maintain water
cycles and climates, both locally and globally. They are the home to
the world's diversity of species and the reference point for
thousands of indigenous cultures and livelihoods around the world.

The biodiversity and livelihoods of Africans should not be considered
expendable for the cause of climate change solutions.

The examples that we cite here from Africa and elsewhere in the world
are likely to be just the beginning of growing and accelerating
trends. These trends will put serious pressure on African
communities to change the crops they grow, their access to land, food
and forests, while our wilderness and forest areas are sacrificed.
If Africa is to attempt to meet the vast energy requirements of the
UK and the rest of the EU, then these impacts will be enormous.

"Sustainable Biofuels"

As you note in your consultation document, there are currently no
internationally agreed definitions of "sustainable biofuels", and
even if there were, any certification schemes might be argued to be
illegal barriers to trade.

However "sustainable biofuels" come to be defined, there can only be
a limited amount that can ever be genuinely sustainable. To meet
projected targets, biofuel production will be inherently
unsustainable, due to the necessary changes in land use and food
supplies that will result from providing enough biofuels to meet
increased targets.

In an African context, we believe that the only
genuinely "sustainable biofuels" will be those that involve crops
that can be integrated into current farming practices, and do not
displace or compete with any land or food crops. From our
persepective, the only sustainable biofuels can be those that are
produced for household, local or domestic use, in order to meet the
energy needs of the poor. To us, the production of large-scale
biofuel crops for export will inevitably displace our agriculture,
and therefore cannot be sustainable.

In response to Question 8 "In advance of internationally agreed
standards, is there more that can be done to ensure that biofuels are
sustainably sourced, for example through voluntary standards or
agreements?"

We would argue that the UK government and the Department of Transport
must refrain from promoting and using biofuels, and raising targets
for now.

In response to Question 14 "Should the government specify that, from
a given date, only those meeting certain minimum environmental and
social standards should qualify for credits under the RTFO. If so,
what standards should be applied, and from what date?"

We warn against placing too much trust in the final definitions of
the term "sustainable biofuels", and believing that all problems can
be solved with such a label. We have heard unsettling rumours that
lead us to doubt the sincerity of stakeholders in the "sustainable
biofuels" discussions. For example, we have heard that the
government is considering awarding sustainable status to biofuels
that have been grown on land that had previously been forested up to
18 months ago. This 18-month delay is to short to be any deterrent
to deforestation, and suggests either naivety or cynicism if true.

We also hear that the UK government's position on whether or not to
allow Genetically Modified (GM) crops to be considered "sustainable"
is not certain. We feel strongly that any crop calling
itself "sustainable" cannot include GM. With the exception of South
Africa, no African countries have commercialised GM crops. This is
due to the serious concerns that African farmers and governments have
about the impacts of patented seeds, crops that only function in
association with specific chemicals, and the high risk of GM cross-
pollination and contamination of local crops. Over the years, Africa
has remained GM-free in the face of strong international pressure to
accept GM crops. Unfortunately, biofuels may provide the entry point
for GM crops into our continent, overriding the interests of African
farmers and the environment.

In response to Question 24 "Will rewarding different biofuels on the
basis of their relative carbon saving performance be sufficient to
bring these fuels onto the market? If not, what other ways might the
government support the development and use of "advanced" renewable
transport fuels?"

If this question refers to the use of GM crops and GM trees as
biofuels, then our concerns have been outlined above. We would also
be extremely wary about any use of GM micro-organisms in the
production of biofuels, due to their ability to rapidly mutate,
exchange DNA and reproduce, and the difficulties in containment.

We note that "sustainability" is not only about carbon. Biodiversity
and livelihoods issues are central to these discussions too, and must
not be compromised.

"Unintended Consequences" and "Environmental Scapegoats"

In the consultation document, you briefly acknowledge the potential
for unintended negative impacts on environment and sustainability,
for example "The RTFO may promote the development of widespread
monocultures that can have multiple adverse impacts." However, you
go on to say "All of these issues may be used by NGOs to attack the
RTFO and perhaps to make it a scapegoat for other unrelated
environmental issues."

This, we feel, is a flippant dismissal of very real problems, which
are likely to be caused by large-scale biofuels developments. We ask
that you do not attempt to dismiss the concerns that NGOs such as
ours may lay at your door, but instead take the opportunity to
consider the impacts that your policies will be having on the lives
of our communities.

In Conclusion

Our contribution to the RTFO consultation may be summarised as:

• We note with regret the failure of the RTFO consultation to
consult with organisations outside of the UK, in particular the
organisations representing the communities most likely to be affected
by increased biofuels targets.

• We ask you to consider the impacts that raising UK biofuels
targets will have on African rural communities, remembering the scale
of land that will be required to meet your energy needs.

• In particular, we are extremely concerned about pressures for
changes in ownership of land and privatisation. The land for large-
scale biofuel production must come from somewhere, whether from small
farmers' land, communal land or conservation areas. There is no free
land in any of our countries, so communities will inevitably be
displaced and denied of their land, territories and natural
resources.

• The UK RTFO is part of the government's commitment to reduce
climate change. We remind policy makers that climate change is not
just about carbon dioxide as an indicator. Biodiversity and
livelihoods issues must be considered as part of any successful
climate change strategy, or you face unacceptably high costs that
render the strategies counter-productive.

• There will be a limit to the amount of agricultural biofuels
that can be produced in a genuinely sustainable manner. Beyond a
certain amount, the necessary changes in land use will inevitably
bring about harmful socio-economic and environmental impacts.

• We fear that definitions of "sustainable biofuels" will be
based on decisions of political convenience, and not on science or
socio-economic expertise. We therefore advise against placing too
much trust in the term "sustainable biofuels" and expecting that the
UK's extensive biofuel demands can be met sustainably.

• Furthermore, if trade considerations ultimately prevent the
RTFO from requiring "sustainable biofuel" standards anyway, then
raising biofuel targets will mean that you are knowingly signing away
our rights, lands and communities.

• We ask you to refrain from increasing the UK's biofuel
targets as a quick-fix replacement to fossil fuels. Instead we urge
the UK government to consider solutions that can increase
localisation and energy efficiency, to support genuinely renewable
options, and to reduce unnecessary transport, industry and
packaging.

Sincerely,

Africa Biodiversity Network (Kenya) - Gathuru Mburu
gathurum@...
Melca Mahiber (Ethiopia) - Million Belay
melca@...
Envirocare (Tanzania) - Abdallah Mkindee
mkindee@...
Climate and Development Initiatives (Uganda) - Timothy Byakola
acs@...
Nature-Tropicale (Benin) - Joséa S. Dossou-Bodjrènou
ntongmu@...