When it comes to reducing greenhouse gases (GEE) for biofuels, the risk of increased deforestation is among the main concerns at the national and international level. Renovabio
in the middle of the years 2000, when the first international policies for the production of biofuels began to be developed, there was a great mobilization in the scientific community to investigate what impacts they would have on land use change (MUT) – technical term to designate all changes in land use, including deforestation for agricultural use - around the globe. Several scientific publications warned of the risk of increased emissions and, from then on, the consideration of the MUT has become indispensable in energy policies. Thereby, the global pressure to prevent deforestation from happening as a result of biofuel production has become immense.
With the signature, in 14 March 2018, of the decree that regulated Law no. 13.576/17, of the National Biofuels Policy (RenovaBio), the next steps for implementing RenovaBio include regulating the certification process. It will take place through resolutions of the National Petroleum Agency (ANP), that will define, for example, the method of calculating the energy-environmental efficiency score - which, in turn, will influence the amount of decarbonization credits (CBios) that each biofuel producer will be able to emit.
The energy-environmental efficiency score will be calculated through RenovaCalc, tool developed by researchers specializing in Life Cycle Assessment. Among the institutions involved are: Brazilian Agricultural Research Company (embrapa), National Bioethanol Science and Technology Laboratory (CTBE), Campinas State University (Unicamp) and Agroicone.
But how will the risk of increased deforestation be handled by RenovaBio? The researchers raised a series of alternatives for considering land use change, based on the scientific literature, current policies and dialogues with actors in the production and certification sector. After a few months of work, the proposal was submitted to the ANP last March.
Basically, biofuel producers will have to meet three eligibility criteria to join the program and be entitled to CBios:
- All certified production must come from area without deforestation after the enactment of the RenovaBio law (26 december 2017);
- The entire area must be in compliance with the Forest Code, through the regularization of the Rural Environmental Registry (CAR);
- The sugarcane and palm production areas must be in compliance with the agroecological zoning of sugarcane and oil palm, defined by Federal Decrees 6.961 e 7.172, respectively. This is the configuration that is currently being analyzed by the ANP and that, coming soon, will be placed in public consultation.
This proposal has a number of advantages when compared to other available alternatives. In US biofuels 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 vetoed areas for the production of biofuels and the direct accounting of land use (dLUC).
Changes are considered direct (dLUC) when they occur within the system of the evaluated product and indirect (iLUC), when they occur as a consequence of dLUC, but outside the rated product system. For example, there is dLUC when sugarcane or soy production expands directly over pastures and there is iLUC when this pasture moves to other areas.
Brazil, on the other hand, appears as a standout in the world context when it comes to land use planning policies. Owner of a vast area of native vegetation - more than 60% of the territory - and of a thriving agriculture in expansion, the country has defined unique legal frameworks in the world to reconcile agricultural production and environmental preservation, such as, agroecological zoning, deforestation monitoring and prevention policies and the forest code.
In the case of RenovaBio, the challenge is to define a strategy that has recognized potential for mitigating GHG emissions associated with MUT, low level of complexity for implementation in the first phase of the program, low certification costs for production units, strong technical-scientific foundation, synergy with land use policies and programs in force in Brazil and internationally, and capacity for compliance and assimilation by the productive sector.
The main advantages of the proposed treatment of MUT in RenovaBio are presented below:
- guarantee a strict control of direct conversion of native vegetation areas, which consists of the type of land use change with the greatest potential for GHG emissions and of greatest concern to the scientific community and society in general. Other common types of MUT have emissions an order of magnitude lower than MUT from native vegetation for agricultural use and are much more dynamic in time – for example, the MUT between pasture, annual crops and cane can quickly alternate over the years. Two other types of MUT could have higher emissions: the conversion of use with permanent crops or with forestry to annual agricultural crops. Nonetheless, they are relatively rare in Brazil, considering the other cases.
- ensures the control of the expansion of biofuels for areas sensitive to its cultivation, as defined in the agroecological zoning and the law for the protection of native vegetation. These instruments do not allow, for example, the expansion of sugarcane and soy over the Amazon forest or the overlapping of production areas with preservation areas, as Areas of Permanent Preservation (APP). Such cases would be associated with a great potential for GHG emissions and could be a matter of great concern for Brazilian and international society.
- It is aligned with territorial planning instruments already established and assimilated by the productive sectors. Thereby, their use as eligibility criteria benefits producers aware of environmental issues, who will probably not have difficulties in getting into RenovaBio, indicating a high capacity for assimilation by the productive sector.
- Tem low cost of proof and certification when compared to other alternatives. All eligibility criteria can be verified remotely by satellite imagery or other available information sources, What, for example, the National Rural Environmental Registry System (Sicar), avoiding, thus, alternatives that require field checks, which can have very high costs.
- Avoids the adoption of more complex models and methods and great methodological uncertainties, like iLUC estimation; the discrimination between levels of pasture degradation, types of native vegetation or types of soil management; and verification of soil carbon stocks. Such uncertainties could trigger great legal uncertainty, in addition to greater costs and time for certification and for the regulation of the program itself.
- Safeguard the program from criticism on promoting competition between food and fuel. Land uses with sugarcane or pastures typically have much higher carbon stocks than annual food crops., I eat rice and beans. The adoption of dLUC models would provide a lower carbon intensity for the expansion of biofuels over annual crops, to the detriment of expansion over pastures and, therefore, would be rewarding competition with food crops, unwanted result in a public policy of this nature.
- Tem synergy with various international standards and scientific literature. The European directive and various international protocols (such as, Bonsucro, ISCC e RSB) make use of risk management mechanisms by establishing 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 target of great criticism and controversy in the scientific community. This background gives the proposal scientific and political robustness in international eyes.
- IT'S transparent and simple communication for the productive sector and society. Direct or indirect MUT accounting involves complex models, difficult to understand by much of society, while the adoption of simple criteria and broad knowledge can bring transparency and facilitate communication.
In short, the proposal is sufficiently robust 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 Renovabio 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.
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