Questions to the project group ‘'Sustainabable production of biomass'’ (Cramer Commission )

Questions to the Project Group ‘Sustainabable Production of biomass
’ [from, when?]

  1. The first part of the assignment of the project group was to “organise a stable structure of consultation and cooperation with stakeholders concerned..”. However, no organisations from the producer countries participated either in the project group, or are listed in the list of stakeholders. Also, the report was not translated in any of the languages of the producer countries, like Spanish. Why were organisations from procuder countries not considered as stakeholders? I notice that the follow up activities do include ‘elaboration of a protocol for the required dialogue with local/national stakeholders with respect to the reporting on sustainability indicators’. Why should they only be consulted on the reporting, and not on the design (or feasibility) of the indicators?
  2. How was the composition of the project group decided upon, and why are NGOs so underrepresented? Did the participating NGOs Oxfam and SNM agree with the entire content of the first report?
  3. I was one of the respondents saying I could not answer the questions of the questionaire, since they seemed to assume that the participants agree with certification in the first place. I noticed that your report states that 68% of the respondents thought sustainability certification for biofuels was possible. What were the reasons given by the other 32% who think this is not possible?
    (The survey report is currently not available on
  4. On what academic discourse is the People, Planet, Profit approach based, and what exact definition of this approach is used by the project group? ‘Profit’ or ‘economic prosperity’ for whom? Especially in producer countries we see that the expansion of monocultures bring profit for some, and unemployment, poverty, health crises and violence for many others. Strong examples of this are the soy expansion in Argentina and Paraguay, and palmoil expansion in Colombia.
  5. What does the project group think about the observation made by Milieudensie, WWF, Greenpeace, and others in their report: ‘Biomass, risks and opportunities' that sustainable biomass for biofuels is not possible without a clear reduction in (soy, palm oil) imports for other uses, like animal feed and food ingredients?
  6. Why does the project group suggest that regarding GMOs, American rules (US I assume) applying till 2010 would be acceptable, whereas these rules are much weaker than the EU rules? It has to be noted that GM applications to soy crops, Roundup Ready technology, combined with no till techniques, has been key in the gigantic expansion of soy production in countries like Argentina, now followed by Brazil and Paraguay, with disastrous consequences for water, soil, regional climate, and now creating herbicice resistant weeds.
  7. Is the project group aware that ‘sustainability’ certification initiatives for commodities undertaken so far are very controversial amongst civil society organisations in the producer countries? The second Round Table on Responsible Soy held in Asuncion, was rejected by virtually all Paraguayan NGOs, and social and peasant movements. The only small farmer organisation involved at the beginning, FETRAF from Brazil, has deliberately left the RTRS. These initiatives are based on voluntary certification.
    If mandatory certification would be introduced for biofuels, does the project group advocate it’s application to all soy uses (food and feed, industrial)?
  8. Which studies has the project group used that indicate that large scale soy production for biofuels would lead to ‘rural development’ (p.5)? Expansion of soy production in Latin America is usually associated with unemployment (hardly any workers needed), violent land conflicts (like recently in Quimili, Santiago del Estero, Argentina), destroyed crops and health crises due to careless use of RoundUp by soy farmers, and migration to the city slums.
    Why would this be different with soy production for biofuels meant for export?
  9. The report states that the production of biomass can contribute both negatively and positively to biodiversity. In what cases would the production contribute positively to biodiversity? At this moment, soy producing regions show to have close to zero biodiversity, both natural and especially agricultural, compared to areas with small scale agriculture. On what grounds has been decided to focus only on ‘high conservation value areas’ where biodiversity is concerned? It seems that allowing regions that don't qualify as such to get covered in monocultures, will eventually contribute to the number of species that are endangered with extinction.
    Has agricultural biodiversity been taken into account by the project group?


  10. In some regions the enforcement of local legislation in insufficient.’ (p.6) Which regions have been identified as such by the project group, and which regions are considered to have sufficient enforcement? More specifically, how does the project group think the criteria can be applied in a country like Paraguay, 4th largest soy exporter, and one of the most corrupt countries of Latin America?