When it comes to reducing greenhouse gas (GHG) emissions from biofuels, the risk of increasing deforestation is among the main concerns at the national and international levels.
In the mid-2000s, when the first international biofuels production policies began to be developed, there was a major mobilization in the scientific community to investigate what impacts they would have on land-use change (MUT) – a technical term to designate all changes in land use, including deforestation for agricultural use – around the globe. A number of scientific publications have warned of the risk of increased emissions and, from then on, consideration of the MUT has become indispensable in energy policies. As a result, global pressure to prevent deforestation from occurring as a result of biofuel production has become immense.
With the signing, on March 14, 2018, of the decree regulating Law No. 13,576 / 17, of the National Biofuels Policy (RenovaBio), the next steps for the implementation of the RenovaBio are regulated by the certification process. This will occur through resolutions of the National Petroleum Agency (ANP), which will define, for example, the calculation method of the energy-environmental efficiency note – which, in turn, will influence the amount of decarbonisation credits (CBios) that each biofuel producer may issue.
The energy-environmental efficiency score will be calculated through RenovaCalc, a tool developed by specialists in Life Cycle Assessment. Among the institutions involved are: Brazilian Agricultural Research Corporation (Embrapa), National Bioethanol Science and Technology Laboratory (CTBE), State University of Campinas (Unicamp) and Agroicone.
But how will the risk of increased deforestation be addressed by RenovaBio? The researchers raised a number of alternatives for consideration of land use change, based on scientific literature, current policies and dialogues with actors in the productive and certification sector. After a few months of work, the proposal was submitted to the ANP in the last month of March.
Basically, biofuel producers will have to meet three eligibility criteria to join the program and be entitled to CBios:
1. All certified production must come from an area without deforestation after the date of enactment of the RenovaBio law (December 26, 2017)
2. The entire area must be in compliance with the Forest Code, through regularization of the Rural Environmental Registry (CAR)
3. The cane and palm production areas should be in accordance with the agroecological zoning of sugarcane and oil palm, as defined by Federal Decrees 6,961 and 7,172, respectively. This is the configuration that is currently being analyzed by the ANP and will soon be placed in public consultation.
This proposal has a number of advantages when compared to other alternatives available. In US biofuel policies, the main way to address this issue is through the adoption of indirect land-use change factors (iLUC factors). In Europe, risk management mechanisms are used, such as the definition of prohibited areas for the production of biofuels and the direct accounting of land use (dLUC).
Changes are considered direct (dLUC) when they occur within the evaluated product system and indirect (iLUC), when they occur as a consequence of the dLUC, but outside the evaluated product system. For example, there is dLUC when cane or soybean production expands directly over pastures and there is iLUC when this pasture moves to other areas.
On the other hand, Brazil appears as a highlight in the world context when it comes to land use planning policies. Owning a vast area of native vegetation – more than 60% of the territory – and booming agriculture in expansion, the country has defined unique landmarks in the world to reconcile agricultural production and environmental preservation, such as agroecological zoning, monitoring policies and prevention of deforestation and the forest code.
In the case of RenovaBio, the challenge is to define a strategy that has recognized GHG mitigation potential associated with MUT, low level of complexity for implementation in the first phase of the program, low certification costs for producing units, strong technical background -experience, synergy with policies and programs of land use in force in Brazil and international, and capacity of compliance and assimilation by the productive sector.
The main advantages of the proposed MUT treatment in the RenovaBio are presented below:
1. It ensures a strict control of the direct conversion of native vegetation areas, which consists of the type of land use change with greater potential for GHG emissions and of greater concern to the scientific community and society in general. Other common types of MUT have emissions of an order of magnitude smaller than the MUT of native vegetation for agricultural use and are much more dynamic in time – for example, MUT between pasture, annual crops and cane can alternate rapidly over the years . Two other types of MUTs could have higher emissions: use conversion with permanent crops or silviculture for annual crops. However, they are relatively rare in Brazil, considering the other cases.
2. It assures the control of the expansion of biofuels to areas sensitive to its cultivation, as defined in the agroecological zoning and the native vegetation protection law. These instruments do not allow, for example, the expansion of sugarcane and soybeans over the Amazon forest or the overlapping of production areas with preservation areas, such as Permanent Preservation Areas (APP). Such cases would be associated with a great GHG emission potential and could be of great concern to Brazilian and international society.
3. It is aligned with instruments of territorial planning already established and assimilated by the productive sectors. As a result, their use as eligibility criteria benefits producers attentive to environmental issues, which will probably not have difficulties in gaining access to the RenovaBio, indicating a high capacity of assimilation by the productive sector.
4. It has a low cost of certification and certification when compared to other alternatives. All eligibility criteria can be remotely verified by satellite imagery or other sources of available information, such as the National Rural Environmental Cadastre System (Sicar), thus avoiding alternatives that require field checks, which can have very high costs.
5. It avoids the adoption of models and methods of greater complexity and great methodological uncertainties, such as the iLUC estimate; the discrimination between levels of pasture degradation, native vegetation types or types of soil management; and the verification of carbon stocks in the soil. Such uncertainties could trigger great legal uncertainty, in addition to greater costs and time for certification and for regulation of the program itself.
6. It shelters the program of criticism on the promotion of competition between food and fuel. Uses of land with sugar cane or pastures typically present much higher carbon stocks than annual food crops, such as rice and beans. The adoption of dLUC models would lead to a lower carbon intensity for the expansion of biofuels on annual crops, to the detriment of the expansion on pastures and, therefore, would be rewarding the competition with food crops, undesired result in a public policy of this nature.
7. It has synergy with various international standards and scientific literature. The European directive and several international protocols (eg Bonsucro, ISCC and RSB) use risk management mechanisms to establish sensitive areas that are closed to the expansion of biomass production for biofuels. On the other hand, the adoption of iLUC factors has been the subject of great criticism and controversy in the scientific community. This history gives to the proposal presented scientific and political robustness to the international eyes.
8. It is transparent and simple communication for the productive sector and society. Accounting for direct or indirect MUT involves complex models that are difficult to understand by much of society, while the adoption of simple and widely known criteria can bring transparency and facilitate communication.
In summary, the proposal is robust enough to ensure safety and low risk of GHG emissions due to MUT and at the same time simple enough to be implemented. If approved, it will make Renewabio an important vector for promoting the sustainable use of land for the production of biofuels and will ensure the maintenance of Brazil’s leading position in promoting sustainable agriculture and energy matrix.