Comments on Draft Biofuels Industrial Strategy

The African Sustainable Fuels Centre (ASFC) has provided us with their comments on the draft Biofuels Industrial Strategy, which contain particular reference to the Feasibility Report that was developed to underpin the draft Strategy.  It was noted in their review of the two documents that the Feasibility Study provides various insights into biofuels, which in many cases fail to find their way in any substantive form into the draft Strategy.  

The main areas of concerns are the impacts on

The agricultural sector, including the impact and price increases on other food sectors such as dairy, meat and other grain crops.  Consumers may be forced to change their food preferences, because of crops being more financial viable as "fuel" rather than "food".

The estimated number of jobs (30 000) talked about in the draft Strategy is based on the assumption that new crops will be planted on new land.  A more realistic number of 4 300 direct jobs created from the biofuels producer and transport sector is given in the feasibility study, although it acknowledges that some jobs will be lost in the oil refinery sector.

A far more detailed analysis of water requirements of the biofuels industry and its impact on the existing water users needs to be undertaken.  This is of paramount importance in a water scarce country such as South Africa.

The question of food security should be addressed in greater detail as there are contradicting statements about short term price increases, and that this would have a limited impact of food security. Clearly if the state must make a choice between food or fuel, its priority must be to feed its citizens.  In Mexico, the price of maize has tripled in price because of demand for biofuels, having a devastating impact on the poor in the country, as maize is their staple food crop.  In South Africa, where 18 million people live on less than R3 per day, the assumption (made in the Feasibility Study) that there is no market for food, and therefore there is a market for fuel needs to be questioned.  It is important to understand the reasons for people not buying food and to address these issues before assuming that the decline in agriculture is due to a lack of local need.

Significant resources have been assigned to the development of the Feasibility Report, which underpins the draft Strategy.  However, there are a number of unknowns and contradictions which need to be resolved.  There are also significant gaps in the research, including

• The issue of biogas is significant by its absence.  No explanation is provided, yet biogas provides a waste to fuel technology, which would impact positively on the rural poor.
• Emerging technologies such as algae technologies, the used vegetable oil market and the use of alien vegetation should be included as part of the research agenda.

It is suggested that biofuels be produced outside the fossil fuel value chain, and should be unlinked to the oil price.  The financial incentives need ot be decoupled from the oil price. 

Small producers, as a separate sector, need to be considered.  It is likely that a different scheme of incentives and financial subsidies is necessary compared to the large oil refineries. 

The National Biofuels Task Team should be enhanced by including non-govermental representation who can input intelligently into the strategy.

The comments on the draft Strategy were offered as constructive criticisms and it is hoped that this and future public participaiton processes can develop a Biofuels Strategy, which will promote ecologically, socially and economically sustainable development.   

For more information about the African Sustainable Fuels Centre : www.asfc.org.za