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Response by five African NGOs to UK biofuel (RTFO) consultation

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  • almuthbernstinguk
    Response to UK Department for Transport Consultation On the Draft Renewable Transport Fuel Obligation May 2007 Africa Biodiversity Network, Kenya Melca
    Message 1 of 1 , May 25, 2007
      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'".)


      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.


      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

      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

      • 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


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