Dear High Level Panel of Experts:
ActionAid USA appreciates the opportunity to comment on the Committee on World Food Security’s (CFS) High Level Panel of Experts (HLPE) V0 draft report on Water and Food Security. ActionAid is an international organization, working in 45 countries to further human rights for all and defeat poverty. Our comments focus on the impacts of biofuels production on water quality and quantity, an important issue that report touches on but, in our view, could expand upon greatly. Biofuels have arisen as an issue affecting not only food security but also water quality and quantity, and challenges will only worsen as global biofuels mandates increase over the coming decade. As the draft report states, “biofuels consume significant quantities of water” and are just one of many industries putting pressure on water supplies around the world. The report draft rightly acknowledges important issues related to increased biofuels production on water availability, water quality, and other socioeconomic impacts, such as increased use of irrigation, loss of land tenure due to international land grabs to grow biofuels feedstocks, and the likelihood that biofuels production fails to benefit smallholder farmers in water scarce contexts.
In addition to these important issues, ActionAid also recommends that the final report include discussions of the following concerns surrounding biofuels’ impacts on water and food security:
(1) The quantity of water used directly in the production of biofuels at ethanol and biodiesel facilities, in addition to biofuels feedstocks such as sugarcane, soy, and corn.
(2) How this demand for water may increase in the future as biofuels mandates are expanded worldwide, for both feedstocks and the production of biofuels at ethanol and biodiesel facilities. The Organization for Economic Co-operation and Development (OECD) and the Food and Agriculture Organizations of the United Nations (FAO) estimate biofuels production to increase 50 to 60 percent over the coming decade; other international estimates, such as those from the International Energy Agency (IEA) predict even greater expansion of global biofuels production over the same time period.i The corresponding increase in water demand and effects on water quality will be immense as first-generation biofuels, produced primarily from food crops, continue to dominate the biofuels market and require large amounts of fertilizer, herbicides, and pesticides. The production of potentially less water- and input-intensive second generation biofuels such as cellulosic ethanol derived from perennial grasses or agricultural wastes has yet to reach commercial production. As the National Academy of Sciences predicted in a 2011
report, companies attempting to produce cellulosic biofuels will continue to struggle with technological and economic challenges, while first-generation biofuels largely produced from food crops continue to degrade water quality and require more water than gasoline in their production process.ii
(3) How water quality issues are exacerbated by biofuels production, particularly in areas growing input-intensive biofuels feedstocks and refining biofuels (such as the American Midwest). Over half of all US waters are impaired or threatened, many the result of agricultural fertilizer and chemical runoff from large-scale farms growing corn and soybeans.iii ActionAid Brazil released a report in Oct. 2014 detailing how smallholder farmers and local communities are no longer able to grow food for their families or local
markets due to the degradation of water supplies and the application of harmful herbicides and pesticides on nearby sugar and soybean fields.iv
(4) How increased water usage for biofuels feedstock production and biofuels production affects food security, both at a local and international level. Currently, approximately
65% of EU vegetable oil, 40% of the US corn crop, and 50% of Brazilian sugarcane are used for biofuels.v Biofuels crops such as corn and soybeans are some of the most water- intensive crops grown around the world. With increased production of food-based, water- intensive biofuels in the coming years, pressure on commodity and food prices will increase as greater percentages of crops are used for biofuels and as price increases encourage large-scale farms to grow fuel instead of food crops. The UN CFS’s expert panel report on biofuels in 2013 noted that “biofuels and more generally bioenergy compete for land and water with food production.” A 2011 report, commissioned by G20
agricultural ministers, recommended that countries “remove provisions of current national policies that subsidize (or mandate) biofuels production or consumption,” acknowledging that biofuels production was a significant factor in increased food price and food price volatility. Other experts have estimated that biofuels production was responsible for 10-15% of food price increases and up to 30% of grain price increases since 2007.vi Impacts will only worsen if food-based and land-intensive biofuels mandates and other subsidies continue on auto-pilot.
(5) How women in particular are affected by the loss of access to adequate, clean water supplies and affordable and nutritious food since they bear the burden of providing food, water, and fuel for their families in many parts of the world. As the report acknowledges, there are “trade-offs between water uses/users [which should be tackled] in an equitable, gender just and deliberative manner.”
The HLPE also welcomed “examples on how the role of water for food security and nutrition is accounted for in land governance and management and land-use, including links between land tenure and water rights.” The land rush for biofuels and other agricultural production has resulted in vast tracts of land being sold or leased to commercial interests, many of which are large multinational biofuels companies or agribusinesses aiming to export biofuels to the EU, US, and other countries with large biofuels mandates. Local communities lose land previously used for farming, animal grazing, fishing and gathering wild foods, as well as for wood and water collection, when land deals prioritize investors and outside interests over local livelihoods.
Biofuel-related land deals displacing local communities have been documented in countries ranging from Cambodia to Tanzania.vii
Finally, we believe there is a typo in the last sentence at end of page 63: the text should indicate that some companies have received water rights even without sufficient water available for such operations, but the word “without” is absent from the sentence.
Thanks again for the opportunity to comment on this draft report as we work towards increasing food security, access to clean water, and land tenure rights for the most vulnerable populations around the world. If you have any questions, please contact me at Kristin.sundell [at] actionaid.org.
Sincerely, Kristin Sundell
i http://www.fao.org/fileadmin/templates/est/COMM_MARKETS_MONITORING/Oilcrops/Documents/OECD_Repor ts/biofuels_chapter.pdf
ii http://www8.nationalacademies.org/onpinews/newsitem.aspx?RecordID=13105,
http://www.nap.edu/openbook.php?record_id=12039&page=45
iii http://iaspub.epa.gov/waters10/attains_nation_cy.control
iv http://www.actionaid.org/sites/files/actionaid/biofuels_energy_hunger.pdf
v
http://www.fao.org/fileadmin/templates/est/COMM_MARKETS_MONITORING/Oilcrops/Documents/OECD_Repor ts/biofuels_chapter.pdf
vi http://www.cbo.gov/sites/default/files/cbofiles/ftpdocs/100xx/doc10057/04-08-ethanol.pdf, http://www.ifpri.org/sites/default/files/publications/vonbraun20080612.pdf
vii http://www.actionaid.org/sites/files/actionaid/the_great_land_heist.pdf
Kristin Sundell