The 2011 Report on Price volatility and food security by the HLPE on Food Security and Nutrition provided well-researched and high-quality evidence about the role of biofuels in recent food price rises and price volatility.
We had therefore anticipated that the draft report “Biofuels and Food Security” by the HLPE on Food Security and Nutrition would build on and further develop the evidence collated for the 2011 report. Instead, we have been deeply disappointed by the low quality of evidence and inaccuracies contained within this draft report. While some paragraphs and statements are based on convincing evidence, so many are not that we believe the report needs to be sent back to be substantially re-written before being put out to public consultation again. Below are examples of some of the serious flaws we have found in the report followed by key concerns about the draft recommendations.

Industrial scale bioenergies, including biofuels are rapidly expanding, creating massive new demand for wood, vegetable oil and agricultural products. Already these demands are inflicting serious and irreversible impacts on forests and other natural ecosystems, soils and water resources. Expansion of industrial monocultures, including tree plantations, to meet this demand occurs at the expense of biodiversity and food production, while also contributing to “land grabs”, undermining the rights of peasant farmers and indigenous peoples, and hampering efforts to achieve food sovereignty and agrarian reform.
The CBD Secretariat's report rightly acknowledges many of these negative impacts. However, in line with COP10 decision X/37, it focuses predominantly on 'tools', i.e. standards and certification, to address the often complex direct and indirect negative impacts, without assessing whether those tools are credible instruments.
Standards and certification schemes per se have not been effective and are no match for countering the drivers of bioenergy expansion: targets, mandates and subsidies, especially in Europe and North America. To effectively address the negative impacts, those incentives need to be eliminated.

In Conclusion: I have wanted to highlight and list a few points that elucidate the shortcomings of the data provided and the risk assessment carried out and provided. These, in my view, give evidence to the necessity to do further indoor trials, reassess the hypothesis and test for health consequences before any open environmental release should or could take place. It should further be deliberated whether the approach taken to address the aphid problem does not in itself cause new problems.