Analysis of RSB Certification

The RSB certification fails
to assess the real impacts of biofuels

Analysis of the RSB certification of Addax Bioenergy
by the Sierra Leone Network on the Right to Food (SiLNoRF)
with complements from Bread for All, Switzerland
Content
Executive Summary ................................................................................................................................. 2

1. Why the RSB is inadequate ............................................................................................................. 3
1.1. Inadequate consultation process of RSB ................................................................................. 3
1.2. Inadequate auditing process of RSB ........................................................................................ 3
1.3. Food security is not sufficiently taken into account ............................................................... 4
1.4. Inadequacy of the water use assessment ............................................................................... 6
1.5. Weak NGO support and business domination ........................................................................ 6
2. What the RSB does not take into account ...................................................................................... 7
2.1. Environmental impact ............................................................................................................. 7
2.2. Cumulative impacts on food security ...................................................................................... 7
2.3. Cumulative impacts on the Rokel river ................................................................................... 8
2.4. Why produce biofuel in food insecure Sierra Leone? ............................................................. 8
2.5. Impact of biofuels on food prices ............................................................................................ 8
2.6. Very favorable contracts, conflict of interests and taxes ........................................................ 9
2.7. Need for a change of paradigm ............................................................................................. 10
3. Conclusion ..................................................................................................................................... 10
Goal of this analysis
In February 2013, Addax Bioenergy announced it had received the Roundtable for Sustainable
Biofuels (RSB) certification for its biofuel project in Sierra Leone. This paper analyses the adequacy of
the Roundtable for Sustainable Biofuels (RSB) certification and auditing process for assessing the
sustainability of the biofuel project of Addax Bioenergy.
1
Executive Summary
On February 28, 2013, Addax Bioenergy announced it had received the Roundtable for Sustainable
Biofuels (RSB) certification for its biofuel project in Sierra Leone.
The main weakness of the Roundtable for Sustainable Biofuels (RSB) certificate is that, when
comparing biofuel with oil, it only takes Greenhouse Gases (GHG) into account and not other
environmental aspects, such as water use and pollution, air and soil pollution, and waste. If the RSB
would do that, they would observe that the environmental impact of ethanol is bigger than the one
of oil (+30% at least). This is the reason why ethanol cannot receive the exemption from mineral oil
tax in Switzerland that has stricter criteria than the RSB for biofuels. Furthermore the procedure for
the Addax certification shows that RSB was looking at sustainability only from a limited perspective
and was neglecting in its approach the two other important pillars of sustainability i.e. social equity
and long-term economic profitability for all stakeholders.
The audit for Addax Bioenergy was the first audit in Africa and the Addax project is very complex,
esp. on social issues like food security. The audit team was just six days on-site and no social expert
was part of it. Therefore, it is not surprising that the assessment of impacts on food security is
inadequate. It did not include information from NGOs monitoring the project showing that Addax
took large tracks of fertile lands from the farmers and that the program of Addax to mitigate its
impact on food security is not working well: yields were low in one of three Chiefdoms because of
late land preparation, infertile soils and/or inadequate seeds. The harvests could not ensure the food
security in this Chiefdom.
More worrying is the fact that the RSB does not analyze the cumulative impact of foreign large scale
agricultural projects in Sierra Leone. Sierra Leone is not food self-sufficient and the malnutrition rate
is higher than 30%. Indeed, many foreign large scale agricultural projects are already documented in
Sierra Leone covering more 20% of the total arable land. The RSB makes no assessment of the
cumulative impact of Addax and other similar projects on food security, water availability and
forests. This is in contradiction of the RSB criteria of assessment of potential impact on food
security and access to water. The RSB fails to assess the real impact of biofuels on affected local
communities.
Also not taken into account are the very favorable contracts signed by Addax: the company received
very generous tax exemptions from the Government of Sierra Leone that will lead to savings of more
than USD 100 million in the next ten years. From a government and development perspective, this
puts question marks on the financial sustainability of the project. The RSB with 48 corporate
members (among them Shell, Petrobras, Airbus, Boeing and Addax Bioenergy itself) is dominated by
business interests. Although it counts 27 NGO members, a true multistakeholder approach is not
ensured, since many of the NGOs are small organizations with a local reach only and CSOs working
directly with affected communities are not consulted.
We are convinced that biofuels, even with a certification, are not the solution to the worlds ever
increasing demand of energy. Whilst we feed cars with cheap crops from the South, food prices
rocket, forests are destroyed and people suffer from hunger. Certifying these crops as sustainable is
a smokescreen that will fool the public and let the problems continue. The real sustainable answer is
to reduce the demand for biofuels and to ensure access to land for farmers.
2
1. Why the RSB is inadequate
1.1. Inadequate consultation process of RSB

The Sierra Leone Network on the Right to Food (SiLNoRF) and Bread for all (BFA) participated in the
public consultation process for civil society organizations (in September 2012) when it was published
that Addax Bioenergy applied for a RSB certification. SiLNoRF and BFA sent two reports to the RSB:
- Annual Monitoring Report on the Operations of Addax Bioenergy for the Period June 2011
June 20121 of SiLNoRF.
- Concerns of civil society organisations and affected land users on Addax Bioenergy2 of BFA
and SiLNoRF.
Both reports show the threats to food security and to the access to water, among many others. No
reference to these reports is made in the audit summary report written by the auditors
commissioned by the RSB. The audit team found some other reports on the Internet but stated that
all the reports found were more than one year old and may not reflect the current situation3.
SiLNoRF is the only NGO in Sierra Leone monitoring independently the operations of Addax
Bioenergy. SiLNoRF has never been contacted by the auditors commissioned by the RSB. Instead,
before the audit, two NGOs, Conservation Society of Sierra Leone and Environmental Foundation
for Africa where contacted by e-mail4. But these organizations never carried out any investigation
into the human rights implications of the Addax operations. Therefore, we seriously question the
adequacy of the consultation process and the inclusion of information from Civil Society
organizations.
1.2. Inadequate auditing process of RSB

Addax Bioenergy was the first biofuel project to be assessed in Africa. The audit team was just six
days on site5. This short period does not seem to be adequate to analyze the complexity of the
environmental and social problems caused by such a large scale project in Africa.
A project, like the one of Addax Bioenergy, is especially complex on social aspects (like the right to
food and the access to water) and needs the expertise of a social expert as well as a human rights
lawyer to be properly assessed. No social expert was part of the auditing team6. Instead, a social
1
The entire report can be downloaded here : https://sites.google.com/site/silnorf/news-1/monitoring-report-july-2012 .
2
The entire report can be downloaded here :
http://www.brotfueralle.ch/fileadmin/deutsch/2_Entwicklungpolitik_allgemein/C_Wirtschaft%20und%20MR/Landgrab/CSO_Conc
erns_Addax_120925.pdf
3
RSB Services Foundation. 2013. Audit report summary for Addax Bionergy Sierra Leone. Accessed under :
http://rsbservices.org/wordpress/wp-content/uploads/2012/01/Addax-RSB-public-cert-report-130214-FINAL.pdf
4
5
6
3
expert has been consulted after the on-site audit7. SILNORF therefore questions the ability of the
auditing team to deal with complex social issues.
Moreover, the RSB audit report summary states that most of the evaluation has been concentrated
on assessments done by the applicant, specialist studies, ESMPs and plans and procedures developed
from the results of the assessments8. We question the adequacy of using mainly company
documentation and not conducting interviews and data collection on the field to assess the project.
The RSB audit report summary also states: Implementation has been checked on-site, but as the
Estate is at the development stage, implementation is not relevant for all parts of the standard
during the initial audit, and because of that compliance for some of the requirements are only shown
through developed procedures9. BFA questions how the RSB can conclude that the project is RSB
compliant knowing that:
- the project is still in the implementation phase and thus changing very quickly;
- the Farmer Development Program (FDP10) will be supported by Addax only during the first
three years (see below on food security);
- the sustainability of the FDP is not granted, and
- the FDP already shows poor results in the first years.
1.3. Food security is not sufficiently taken into account

It is a minimum requirement of the RSB that biofuel operations shall ensure the human right to
adequate food and improve food security in food insecure regions11.
Regarding food security, the Monitoring Report of SiLNoRF12 showed the following positive points
and negative concerns.
Among the positive points were:
Addax claims to have developed more than 1500 hectares of community fields. This report
confirms that Addax ploughed and harrowed community fields as part of the Farmer Development
Program in every affected community in 2011 (except for the Woreh Yeamah village). The FDP farms
did well in some of the communities, especially in the Malal Mara Chiefdom [one of the three
Chiefdoms affected by Addax] where good harvests in 2011 were recorded.
However, the same report13 also highlighted the following concerns:
7
8
9
10
In order to mitigate potential impacts on food security, Addax Bionergy has established the Farmer Development Program
(FDP). Under the FDP, Addax is helping communities with harrowing during the first three years. During the fourth year, farmers
have to pay the full costs.
11
Roundtable for Sustainable Biofuels. 2010. RSB Principles & Criteria for
Sustainable Biofuel Production. Accessed under : http://rsb.org/pdfs/10-11-12-RSB-PCs-Version-2.pdf
12
Sierra Leone Network on the Right to Food (SiLNoRF). 2012. Annual Monitoring Report on the Operations of Addax
Bioenergy for the Period June 2011 June 2012. Accessed under: https://sites.google.com/site/silnorf/news-1/monitoring-
report-july-2012
13
report-july-2012
4
- SiLNoRF interviewed many communities in the Makari Gbanti Chiefdom (including Lungi
Acre, Woreh Yeama, Yainkasa, Maronko) who indicated that the 2010 and 2011 rice harvests
on the FDP fields were low and therefore not sufficient to ensure their food security. The
reasons of the low rice harvests were the late land preparation by Addax tractors and the
fact that many communities could not afford the costs of fertilizers. Moreover, some
communities reported that the quality of their seeds were poor or not adapted to their type
of soils. Some communities reported that different seed varieties were mixed (seeds were
not pure) and this definitely affected the yield. It was also reported by some communities
that weeding was a serious problem in certain FDP fields because of too much grass.
Communities reported that they have to repay the seeds and the fertilizers to Addax with
rice. Some communities reported that they had not sufficient food after this repayment14.
- Community members at Woreh Yeama even reported to suffer from hunger, because of the
too small area of FDP fields and poor harvest15.
Regarding the sustainability of the FDP, SiLNoRF also noted:

- The FDP relies on expensive external inputs, such as chemical fertilizers and pesticides, and
improved and/or hybrid seeds bought from agribusiness companies. This comes at the
expense of promoting sustainable agriculture approaches which are likely to benefit poor
farmers much more16. Farmers get dependent on expensive inputs, resulting in high costs
that endanger economic sustainability.
- Under the Farmer Development Program, Addax is helping communities with harrowing
during the first three years. During the fourth year, farmers have to pay the full costs. Will
the farmers be able to pay the full costs from the fourth year on? Addax has the obligation to
keep it in place all time in so far as the operations will aggravate food insecurity in the
communities17.
For the issue of food security (as well as for other issues), the auditors of the RSB relied mainly on
information of Addax Bioenergy (see part on auditing process). For instance on this information:
Addax stated that the Farmer Development Program (FDP) has resulted in a harvest of 1600 metric
tons of rice in 201218. This information has been contested by SiLNoRF in its report: community
members interviewed by SiLNoRF reported that the weightings of the harvested rice were biased as
many rice bags contained leaves and stems. Therefore, this figure of 1600 tons is clearly
overstated19.
14
report-july-2012
15
report-july-2012
16
report-july-2012
17
report-july-2012
18
Presentation of Addax Bioenergy made at the Global Land and Poverty Summit. Available here : http://www.swedfund.se/wp-
content/uploads/2012/05/Addax-Bioenergy-World-Bank-conference-on-Land-and-Poverty-26-April-2012.1.pdf .
19
report-july-2012
5
1.4. Inadequacy of the water use assessment
The RSB has the following minimum requirement: The use of water for biofuel operations shall not
be at the expense of the water needed by the communities that rely on the same water source(s) for
subsistence.20
However, Addax will use 26% of Sierra Leones largest river flow (Rokel river) during the driest
months (February to April)21. This figure is not acknowledged by the company, as it tends to refer
only to an annual average of 2% water abstraction. There is no sign of it in the Audit Report Summary
that the auditors were aware of this very important fact.
1.5. Weak NGO support and business domination

The RSB Services Foundation states that it has an unmatched NGO support22. However, the RSB is
dominated by businesses with 48 members being corporations (some of them are very large such as
Shell, Petrobras, Airbus, Boeing) or business associations (such as the IATA). Addax Bioenergy itself
also figures as a member a fact which deeply questions the independence of the certification.
Among NGO members only 16 environmental NGOs (many of them are small organizations with a
local reach, apart from the WWF) and 11 social NGOs (many of them are small organizations with a
local reach). No large human rights or development NGO active on the right to food is a member.
20
Roundtable for Sustainable Biofuels. 2010. RSB Principles & Criteria for Sustainable Biofuel Production. Accessed under :
http://rsb.org/pdfs/10-11-12-RSB-PCs-Version-2.pdf
21
Bread for all and SiLNoRF. 2012. Concerns of civil society organisations and affected land users on Addax Bioenergy.
Accessed under:
erns_Addax_120925.pdf.
22
RSB Services Foundation website. 2013. Accessed under: http://rsbservices.org/.
6
2. What the RSB does not take into account
2.1. Environmental impact

The RSB only analyses the Greenhouse Gas (GHG) balance of biofuels, when comparing them with
petrol. However, GHG emissions are only one environmental impact among many others, like surface
and ground water pollution, air and soil pollution, waste production, biodiversity destruction and
resource consumption. Taking into account all environmental impacts gives a more accurate view of
the overall impact of a project or a product. A study conducted by the EMPA23, a Swiss research
institute, calculated that ethanol from Brazilian sugarcane has a 30% resp. 200% higher
environmental impact than low sulphur petrol depending on the impact assessment method used
(ecological scarcity method and Eco Indicator 9924 respectively).
This means that, in Switzerland, the bioethanol of Addax Bioenergy would probably not be exempted
from the mineral oil tax. This because biofuels in Switzerland have to fulfil strict environmental
requirements (set in the Biofuels Ordinance) to be granted an exemption: they have to emit at least
40% less GHG emission than petrol. Moreover, their environmental impact (measured with the
ecological scarcity method) cannot be more than 25% higher than the impact of petrol.25 If biofuels
do not fulfil these criteria, they are not exempted from the mineral oil tax. And without the tax
exemption, biofuels are not economically viable.
2.2. Cumulative impacts on food security

In Sierra Leone, many other land lease agreements have been or are being signed by investors. The
area covered under these agreements represent in total up to 1.2 million hectares (or 21% of Sierra
Leones land suitable for cultivation)26.
The cumulative impact of these land deals on Sierra Leones food security and food sovereignty has
not been analysed by the auditors of the RSB.
A study on land availability in Sierra Leone states that there is no remaining potential to significantly
enlarge the area under cultivation anywhere in Sierra Leone27. BFA is concerned about the huge
conflict potential over land for subsistence food production in Sierra Leone, a country that is still
recovering from civil war.
23
Zah, Rainer, et al. 2007. Life Cycle Assessment of Energy Products: Environmental Assessment of Biofuels. St-Gallen.
EMPA, p. V and IX. Accessed here: http://www.news-service.admin.ch/NSBSubscriber/message/attachments/8514.pdf
24
The ecological scarcity method permits impact assessments of life cycle inventories according to the distance to target
principle. Eco-factors, expressed as eco-points per unit of pollutant emission or resource extraction, are the key parameter used
by the method. Source: Swiss Federal Office of the Environment FOEN (2009). The Ecological Scarcity Method Eco-Factors
2006 A method for impact assessment in LCA. Berne.
http://www.bafu.admin.ch/publikationen/publikation/01031/index.html?lang=en. The Eco Indicator 99 method is a damage
oriented method for Life Cycle Impact Assessment. Source: Goedkoop, M. and R. Spriensma, The Eco-indicator 99: A damage
oriented method for Life Cycle Impact Assessment. 2001, PR Consultants B.V., Amersfoort, NL.
25
Ordinance on Proof of the Positive Aggregate Environmental Impact of Fuels from Renewable Feedstocks (Biofuels Life Cycle
Assessment Ordinance, BLCAO), of 3 April 2009. Accessed here: http://www.admin.ch/ch/e/rs/6/641.611.21.en.pdf .
26
Accessed under:
27
Bald, Joachim and Schrder, Peter. March 2011. Study on Rural and Agricultural Finance in Sierra Leone: Product Innovation
and Financial Access. Deutsche Gesellschaft fr Internationale Zusammenarbeit (GIZ) and German Federal Ministry for
Economic Development and Cooperation (BMZ). Cited in : Green Scenery Briefings: Land Investment Deals in Sierra Leone
September 2011. Accessed under: www.greenscenery.org.
7
2.3. Cumulative impacts on the Rokel river
The cumulative impact of these land deals on Sierra Leones water availability has not been analysed
by the auditors of the RSB. Many land grabbing projects are located along the Rokel river, the largest
river in Sierra Leone, where they pump water for irrigation. Bread for all is concerned that
downstream users will be impacted negatively if one single user (i.e. Addax) pumps 26% of the river
flow during the driest months28.
2.4. Why produce biofuel in food insecure Sierra Leone?

When assessing and certifying a project in a country, the RSB does not take into account the level of
malnutrition in this particular country nor whether this country is food self-sufficient. Therefore, BFA
thinks that it does not make sense to produce biofuels for export in a country which is not food self-
sufficient, as Sierra Leone and where malnutrition affects one third of the population29. Moreover,
according to the Global Hunger Index 2012, Sierra Leone is ranked 71st out of 79 countries30.
2.5. Impact of biofuels on food prices

The Addax project intends to transform food (sugarcane) into ethanol for cars in the EU. The EUs
biofuel target has created a large demand for biofuels and many projects, like the Addax one, have
started as a response to the biofuel demand created by the EU target. This EUs biofuel target has
however many negative consequences on the Global South.
Among these, the following consequences are the most worrying:

The EUs biofuels policies alone could push up oilseed prices by up to 33%, maize by up to
22%, sugar by up to 21% and wheat by up to 10%, between now and 202031.
Achieving a 10%biofuels share in transport fuel globally by 2020 could put an extra 140
million people at risk of hunger, with the poor urban population, subsistence farmers and the
landless in developing countries particularly at risk32.
Biofuels may drive more than 50% of large-scale land acquisitions globally, and 66% in
Africa33.
It is interesting to note that even BioFuels Switzerland (the Swiss association for biofuels) has very
clear position on the food vs. biofuel debate. On its website, it states: Food crops must first be
used for human food, then animal feed and lastly for biofuel production34.
28
Accessed under:
29
Accessed under:
30
International Food Policy Research Institute. 2013. Global Hunger Index 2012. Accessed under:
http://www.ifpri.org/publication/2012-global-hunger-index .
31
ActionAid. Fuel for thought. Addressing the social impacts of EU biofuels policies. April 2012.
Accessed under: http://www.actionaid.org/sites/files/actionaid/fuel_for_thought.pdf.
32
Oxfam International. EU renewable energy strategy ignores impact of biofuels on food security. June 2012. Accessed under:
http://www.oxfam.org/fr/node/26506.
33
International Land Coalition. Land Rights and the Rush for Land. Findings of the Global Commercial Pressures on Land
Research Project. January 2012. Accessed under:
http://www.landcoalition.org/sites/default/files/publication/1205/ILC%20GSR%20report_ENG.pdf.
34
Biofuels Platform (internet site). Accessed under: http://www.biofuels-platform.ch/en/infos/food.php.
8
A sustainability certificate cannot solve the problem of competition (direct and indirect) between the
production of crops for food and for biofuels. The RSB is not able to consider and even less to
prevent the negative effects of biofuels competing with food crops and increasing food prices as well
as the cumulative impacts on food security and water use mentioned above.
2.6. Very favorable contracts, conflict of interests and taxes

The issues of very favorable contracts, conflicts of interests and taxes are also not taken into account
into the RSB criteria.
Very favorable contracts

A Human Rights Impact Assessment of the Land Lease Agreement (LLA) has been made by a human
right lawyer in Sierra Leone. It highlights that, according to Land Lease Agreement (LLA) signed by
Paramount Chiefs and the Company, all disputes have to be referred to London. This amounts to a
denial of justice given the financial impossibility for landowners to fund their travel and legal
representatives35.
Addax received an exemption to comply with any new law that has a material adverse effect on
Addax and its contractors (change in law clause of the Memorandum of Understanding). BFA is
concerned about this clause which prevents the Government of Sierra Leone from ensuring that
Addax complies with all laws in Sierra Leone36. This is in contradiction with the RSB criteria to comply
with national legislation.
Conflicts of interest
Projects which involve Land Grabbing are subject to high corruption risks, especially in Sierra Leone, a
country which is ranked under the most corrupt countries. In this context, the report strongly
questions the compensation system of Addax: it might have ensured the cooperation of every level
of national and regional authorities, as the District Council and the Chiefdom Administrators receive
annual lease fees without suffering any damage37. Paramount Chiefs that signed the Land Lease
Agreement on behalf of the land owners receive an average of USD 26000 per year38.
Tax exemptions
The Sierra Leonean government granted Addax different tax exemptions and deductions, which will
hinder the State of Sierra Leone to levy a fair share of tax from the company. In the next 10 years,
Addax will be able to save more than USD 100 million in taxes39. From a government and
development perspective, this puts question marks on the financial sustainability of the project.
35
Accessed under:
36
Accessed under:
37
Accessed under:
38
Calculation of Bread for all based on Bread for all and SiLNoRF. 2012. Concerns of civil society organisations and affected
land users on Addax Bioenergy. Accessed under:
erns_Addax_120925.pdf
39
Unpublished study of Green Scenery and ALLAT. To be published in April 2013.
9
Further, the corporate structure of Addax, involving tax heavens, increases the risk that the company
evades taxes. The analysis of the value added sharing demonstrates that the project will mainly
benefit to the company (80% of the total value added), while other stakeholders profit marginally
(for instance, land owners receive 0.7% of the total value added)40.
2.7. Need for a change of paradigm

We are convinced that biofuels from food crops, even with a certification, are not the solution to the
worlds ever increasing demand of energy. Whilst we feed cars with cheap crops from the South,
food prices rocket, forests are destroyed and people suffer. Certifying these crops as sustainable,
even if well intentioned, is a smokescreen that will fool the public and let the problems continue 41.
The really sustainable answer is to reduce the demand for biofuels and to secure access to land for
farmers.
3. Conclusion
The RSB certification scheme does not have adequate criteria for assessing a biofuel project in Africa.
When comparing biofuels with petrol, all environmental impacts should be included (not just GHG
emissions). The impact of food security locally is not sufficiently taken into account, neither is the
cumulative impact of biofuel projects in Sierra Leone on food security, water availability and forests.
Moreover, the fact that biofuels compete with food crops and increase food prices is not included in
the scheme. The auditing process does not seem adequate neither. Therefore, certifying biofuels as
sustainable is a smokescreen that will fool the public as biofuels from food crops are not the solution
to our ever increasing demand of energy.
40
Accessed under:
41
Friends of the Earth website. Accessed under : http://www.foei.org/en/media/archive/2008/green-schemes-for-biofuel-crops-
set-to-fail?searchterm=roundtable+biofuels.
10

Analysis of RSB Certification

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Analysis of RSB Certification

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The RSB certification fails

to assess the real impacts of biofuels

by the Sierra Leone Network on the Right to Food (SiLNoRF)

with complements from Bread for All, Switzerland

Executive Summary ................................................................................................................................. 2

Goal of this analysis

1.1. Inadequate consultation process of RSB

1.2. Inadequate auditing process of RSB

1.3. Food security is not sufficiently taken into account

Among the positive points were:

However, the same report13 also highlighted the following concerns:

Regarding the sustainability of the FDP, SiLNoRF also noted:

1.5. Weak NGO support and business domination

2.1. Environmental impact

2.2. Cumulative impacts on food security

2.4. Why produce biofuel in food insecure Sierra Leone?

2.5. Impact of biofuels on food prices

Among these, the following consequences are the most worrying:

2.6. Very favorable contracts, conflict of interests and taxes

Very favorable contracts

2.7. Need for a change of paradigm

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