© Partners for Innovation
Or... moving forward towards a useful application of the MBSF Project steering: DNER (representing the CIB Technical Commitee) Project funding: NL Agency (Ministry of Foreign Affairs Netherlands) CEPAGRI Mozambique Implementation: Partners for Innovation BV Update: 31 October 2013 Occasion: Workshop for stakeholers, Beira, 31 October 2013
Piloting the Mozambican Biofuel Sustainability Framework (MBSF)
Peter Vissers, Managing Director
João Chidamoio, Senior Biofuel Expert
1
Table of contents
1. Work plan: a. Profile of Partners for Innovation 3 b. Work plan with objectives, approach, roles, planning
and expected results 5
2. Provisional results: a. R1 – three companies applied the MBSF 11 b. R2 – a government delegation monitored the
MBSF application at these 3 companies 21 c. R3 – all participants drafted lessons learned,
conclusions and recommendations 30 d. R4 – a dissemination workshop will be held in
Beira in Oct/Nov 2013 40
2
About Partners for Innovation
Partners for Innovation is a
leading consultancy for
sustainable innovation based in
the Netherlands.
Together with our clients we
achieve profitable solutions for a
biobased and circular economy.
In Africa we focus on profitable
and responsible biomass chains
and agroforestry. We have
worked on this topic in Ghana,
Niger, Nigeria, Madagascar,
Mozambique, Senegal, South-
Africa, Zambia and Zimbabwe.
Our ambition is to help biomass
and agroforestry actors to be
succesfull.
3
About Partners for Innovation (selected references)
Profitable and Responsible Biomass Chains Capacity building on certification standards (NL Agency, Jatropha Alliance, WWF Madagascar, etc) Business plan development (Bio2Watt, E+Co, Green Resources, Wakawaka, etc) Carbon credit development (Bio2Watt, etc) Scaling up agroforestry (Oxfam Niger, Nigeria, Senegal, Zimbabwe, CleanStar Mozambique etc) Sustainability indicators (Ghana Energy Commission)
Sustainable Energy for All & Climate Policy Renewable energy potential in EDCs (EC) Climate policy (Efico, BTC-CTB, etc) Carbon footprint (Sunbiofuels, Triodos bank, etc) NL investors mission South Africa renewable energy
Product Innovation EcoDesign training (DAF Trucks, SITA, Dorel, etc.) Sustainable packaging (NVC, Schoeller Alibert, etc.) Cradle to Cradle (Desso, Vanderlande, etc.)
4
The MBSF pilot – what are the objectives of the pilot?
Two objectives:
1. Build up experience amongst biofuel companies and relevant
government institutes with the application of the biofuel
sustainability framework for Mozambique by carrying out pilots
in the field, and;
2. Evaluate these experiences and formulate practical
recommendations to industry and to the inter-ministerial
subgroup.
5
Vision – why a pilot?
1. The biofuel sustainability framework provides Mozambique with a powerful and practical tool to assess and monitor biofuel projects
2. The sustainability framework is a thorough and comprehensive work. It would, however, benefit from piloting > to determine its value and feasibility on the ground, and > to augment its practicality
3. Piloting is extremely important given the limited available
monetary and human resources at both the companies and the government organizations involved
6
Vision – what is crucial for a successful pilot?
1. Endorsement by the CIB technical committee and the participating governmental organizations; buy-in from the biofuel private sector; acknowledgement from other biofuel stakeholders
2. Learning-by-doing should be the heart of the work. The only way to build up capacity with the sustainability framework, and to assess its practicability and feasibility on the ground, is that the biofuel private sector and the government actually use the framework and really start to work with it
3. Our role is hence to support the biofuel private sector and the governmental monitoring delegation to apply the framework, NOT to collect the info and assess compliance for them
4. A straightforward approach – hands-on and easy to understand.
5. Use the sustainability framework AS IT IS at project start
6. Clear tasks and roles for all actors involved. Flexibility for unforeseen developments
7. Confidentiality and mutual trust. For all involved, the pilot should not lead to any problems afterwards
8. A trusted and competent team having hands-on experience with design and application of sustainability frameworks as well as with the biofuel situation in Mozambique, and having the right language mix (Portuguese/English)
7
Work plan – what is the approach of the pilot?
8
Work plan – which roles have the actors of the pilot?
Actor Suggested role and activities
AGNL Funding partner. Contract partner for Partners for Innovation.
DNER Coordinating implementing partner. Co-organises the project, together with CEPAGRI and the other organisations of the CIB Technical Committee
Partners for Innovation Implementing organisation. Co-organises and implements the project.
CIB Technical Committee
Co-organises the project through DNER. Is informed on progress in CIB Technical Committee meetings.
Monitoring delegation (11 persons)
Visits the 3 pilot projects and assesses their compliance. Attends the workshop and the monitoring visit. Evaluates the process. Presents the lessons learned at the seminar. Is composed of 11 persons representing national and provincial levels of CEPAGRI, CPI, DNAIA, DNER and DNTF. Participation requested of Ministry of Labour but not obtained.
Biofuel pilot companies (3 companies)
Apply to become a pilot company. Fill in the self-assessment. Host visit of Partners for Innovation, and then of the monitoring delegation and Partners for Innovation. Evaluate the process. Present the lessons learned at the seminar.
Other stakeholders Are invited to the final seminar (as well as all actors mentioned above).
9
Work plan – what do we expected to achieve at project end?
Four concrete results:
1. Three biofuel project developers have used the sustainability framework to pilot assess their compliance against the framework, and have undergone a pilot monitoring visit;
2. The monitoring delegation has used the sustainability framework to pilot assess the compliance of three project developers;
3. The experiences of these pilots are evaluated, lessons learned identified, conclusions and recommendations are drawn;
4. Interested Mozambican biofuel stakeholders have had access to the findings of the pilot through a seminar and a final report
10
R1 – Sugar cane company GEZ made a MBSF self-assessment
11
R1 – Jatropha company NiQel made a MBSF self-assessment
12
R1 – Food-energy company CleanStar made a MBSF self-assessment
13
R1 – Each company assessed itself against each verifier of the MBSF
14
TAB3. ASSESSMENT
>> Below the self-assessment fields that companies and government delegation fill in during the pilotCOMPANIES GOVERNMENT
MBSF requirements Self-assessment
Source: draft regulation MBSF (v3 Feb 2013) Guidance ComplianceEvidence Justification scores Evidence list Observation
Nr Verificadores Guia de
avaliação
Guidance developed for
pilot (beyond draft
regulation)
Self-
assessme
nt score
Self-
assessme
nt score
Companies explain in a few words the score for compliance. (Note: in the MBSF pilot it was decided
to focus CSM's self-assessment on its Sofala activities. CSM's bottling factory and sales activities in
Maputo are hence not part of the assessment)
Companies list the available
evidence. Evidence not
available or not in Dropbox:
lower score
Government
officials put
remarks
1. Legalidade
Princípio 1: as operações de Biocombustíveis cumprem as obrigações prescritas na lei e obedecem as ordens emanadas pelas autoridades legítimas com respeito pelos direitos fundamentais.
Principle 1: Biofuel operations respect all applicable laws, regulations and legal procedures
Critério 1.1: Operações de Biocombustíveis devem estar em conformidade com todas as leis, políticas e estratégias aplicáveis e com o respeito a todos os direitos costumeiros existentes, relacionados com o uso e acesso à terra, água e outros recursos naturais.
Criterion 1.1: Biofuel operations shall comply with all applicable laws, policies and strategies and with all existing customary and informal rights related to the use and access to land, water and other natural resources.
Indicador 1.1.1: O operador de Biocombustíveis fornece evidência demonstrando o cumprimento das leis, regulamentos e procedimentos legais aplicáveis e dos direitos costumeiros.
Indicator 1.1.1: The biofuel operator provides evidence demonstrating compliance with the applicable laws, regulations and legal procedures and with the informal and customary rights.
1.1.1.1 Constituição da
República de 2004
Nº 3 do artigo
2, artigo 38, nº
2 artigo 46.
General Mozambican
legal framework
Not
applic.
(NA)
Not
applic.
(NA)
NA NA NA
1.1.1.2 Lei nº 16/91, de 3 de
Agosto, (Lei de Águas).
Artigo
25,27,32,35,37
Licence/concession for
the use and benefit of
water
Full
complianc
e (100%)
Partial
evidence
(75%)
A water use license / concession does not seem necessary since the activities use low amounts of
water. In Dondo the operations use water from CSM's rain collection bassin and from its
borewhole. In Tsawane there is a borewhole. The expected water use of the factory is less than
8m3/hr according to the EIA p78/79. The ARA Centro water invoices CSM for annual consumption
in 2011 and 2012 of 450m3/a. Full compliance, partial evidence (evidence that a water use licence
is not required is missing).
Available in dropbox: EIA 2012,
invoice of ARA Centro 2012.
Not available: evidence that no
water licence/concession is
required
1.1.1.3 Diploma Ministerial nº
7/2010, de 6 de Janeiro,
(modelos de licenças e
concessões de água)
Licence/concession for
the use and benefit of
water
Full
complianc
e (100%)
Partial
evidence
(75%)
As 1.1.1.2 As 1.1.1.2
1.1.1.4 Lei n.º 20/97, de 1 de
Outubro, (Lei do
Ambiente).
Artigo
15,16,17.
EIA if required
(full/simplified).
Environmental licence.
Approval lettre of MICOA
Full
complianc
e (100%)
Partial
evidence
(75%)
EIA. CSM completed a simplified Environmental Impact Assessment (EIA) for its factory producing
ethanol from cassave in Dondo and for its 2 main Community Processing Centres (CPCs) located
near Mezimbite and near the Administrative post of Savane. The EIA concludes that the activities
are environmentally viable (p13). In terms of negative impacts, the EIA identifies 1 high, 12
medium and 8 low impacts, and has formulated mitigation measures. In terms of positive
impacts, the EIA has identified 3 high and 3 medium impacts. The EIA refers to 8 management
programmes (Social Communication Program, Program for Personnel Training and Operating,
Environmental Education Program, Signaling Program, Reforestation Program, Assistance
Program for Families Involved in the Project, Recovery Program Contaminated Soils, and
Monitoring Program Water Quality Artificial Pond) (p137), and defines 12 monitoring actions and
includes 8 monitoring tables. CSM has obtained an environmental licence. Full compliance, full
evidence.
EIA compliance and impact monitoring. CSM indicates to implement the project as described in
the EIA. There is evidence for this since CSM has management programmes in place that cover
the above programmes (e.g. its HSE programme) and monitors the effectiveness of these
programmes (e.g. incident reporting in HSE programme). There is also evidence that CSM
monitors well its obligations regarding EIA: in July 2013 CSM submitted an addendum EIA for use
of molasses to Sofala MICOA. CSM has furthermore developed a framework to monitor the social,
environmental and economic impacts of its activities (IASA framework). Regarding compliance
with the EIA, however, it is not clear whether CSM complies with all programme and monitoring
engagements of the 2012 EIA. Full compliance, partial evidence.
MICOA inspection. There was a recent visit of MICAO which lead to the recommendation to
monitor the soil quality of land on which organic wastes of the ethanol facility were used as
fertilizer. An internal report is available (but not yet in Dropbox). Full compliance, partial
evidence.
Available in Dropbox: EIA 2012,
Governor/MICOA letters 2011,
2012. Env licence 2012. 2013
letter to MICOA Sofala
regarding use of molasses. 2013
addendum EIA for use of
molasses. 2013 presentation on
IASA framework. 2013 IASA
tool.
Not available: evidence of
compliance with programme
and monitoring engagements
of the EIA, internal report on
MICAO inspection
R1 – Each company stored supporting evidence in Dropbox (average 400MB)
15
R1 – Pilot compliance is high (92-97%); supporting evidence is lower (70-85%)
16
Company Pilot compliance with MBSF MBSF follow-up Pilot evidence GEZ 97% = full compliance (90%-100%) > No follow-up 79% NiQel 92% = full compliance (90%-100%) > No follow-up 70% CSM 94% = full compliance (90%-100%) > No follow-up 85% (after verification by monitoring delegation, reference to MBSF version Oct 2013)
0%
20%
40%
60%
80%
100%1. Legalidade
2.Responsabilizaçã
o Social
3. ConsultaPública
4. SegurançaEnergética
5. ViabilidadeEconómica e
Financeira
6. SegurançaAlimentar
7. ProdutividadeAgrícola
8. ProtecçãoAmbiental
MBSF self-assessment: compliance
GEZ
NiQel
CSM
0%
20%
40%
60%
80%
100%1. Legalidade
2.Responsabilizaçã
o Social
3. ConsultaPública
4. SegurançaEnergética
5. ViabilidadeEconómica e
Financeira
6. SegurançaAlimentar
7. ProdutividadeAgrícola
8. ProtecçãoAmbiental
MBSF self-assessment: evidence
GEZ
NiQel
CSM
R1 – The companies found applying the MBSF hard work, but useful + fun
17
R2 – Eleven government officials were on the 6-days monitoring visit
1. Ministério da Energia - DNER Issufo Juma
2. Ministério da Agricultura - CEPAGRI Jorge Manuel Manjate
3. Ministério da Agricultura - DNTF Osvaldo Manso
4. Ministério da C. A. Ambiental - DNAIA Bento Natal C. Joaquim
5. Centro de Promoção de Investimentos CPI Julio Antonio
6. Direcção Provincial R. Minerais Sofala Jorge Arnaca
7. Direcção provincial de Ambiental Sofala Cesario Jose Fernandes
8. Direcção provincial de Agricultura Bernardo Fernando
9. CEPAGRI - Delegação Manica Ester Jacinta
10. CEPAGRI - Delegação Zambézia Nelson dos Santos Sacoor
11. CEPAGRI - Delegação Zambézia Renato Martins
12. Partners for Innovation / UEM João Chidamoio
13. Partners for Innovation Peter Vissers
18
R2 – The monitoring delegation verified the MBSF application at 3 companies
Typical program (start 8H, end 15H):
A. Arrival, welcome by the company, setting agenda
B. Plantation tour
C. (lunch)
D. Questions & answers session
E. Verification of self-assessment, discussion of scores and underlying evidence. Up- or downgrading of self-assessment scores upon consensus
F. Evaluation and recommendations
G. Group photo and end-of-visit
19
R2 – The MBSF application was verified in a respectful and friendly process
20
R2 – The start of the visit process was a plantation tour
21
R2 – The plantation tour provided good insight in the situation in the field
22
R2 – A Q&A session allowed a thorough understanding of the company activities
23
R2 – Self-assessment scores and their justification were verified in consensus
24
R2 – A group photo marked the end of each visit of the monitoring delegation
25
R2 – Each visit resulted in concrete recommendations for the companies
For example >> Q13 Do you have recommendations for company A? 1. Organize all evidence of activities not registered and ask the CPI benefits according
to the CBF!! 2. The environmental component and the implementation of the environmental
management plan should be strengthened further 3. The company should document the facts to serve as proof / evidence 4. The company must comply with all laws and recommendations of the team's
findings 5. Segregation of waste in the workshops, comparative table of emissions / carbon
capture by biomass 6. Enjoy the maximum available local resources such as the case of the wood
commercially existing at the time of drop for social use 7. Document their interactions with the community to be more transparent and
supporting about the steps forward 8. Involve a Mozambican technician to accompany the work of foreign agronomist
26
R3 – Government participants were very satisfied on the self-assessment process
27
>> Average score is 4.4 >> Meaning between 4. “good” and 5. “very good”
1,0 1,5 2,0 2,5 3,0 3,5 4,0 4,5 5,0
The visit and discussions allowed me tounderstand how the MBSF can be applied in
practice
The visit and discussions allowed me tounderstand the value of the MBSF
The self-assessment allowed me to checkwhether the compliance was supported by
evidence
The self-assessment allowed me to have agood insight in how the company complies
with the MBSF
The self-assessment matched the situation inthe field
Evaluation: the 11 government delegation members are satified about the pilot self-assessment proces
Average scoree= 4,4 out of 5,0. Scores range from 1 "I strongly disagree" to 5 "I strongly agree".
R3 – Companies were very satisfied about the pilot self-assessment process
28
>> Average score is 4.3 >> Meaning between 4. “good” and 5. “very good”
1,0 1,5 2,0 2,5 3,0 3,5 4,0 4,5 5,0
The field visits and assessment process wereuseful to understand how the MBSF will work
in practice
The field visits and assessment process wereuseful to assess the compliance of our
company
The information meeting on 22 March wasuseful to understand the pilot
Evaluation: the 4 company participants are satified about the pilot and the field visit
Average scoree= 4,3 out of 5,0. Scores range from 1 "I strongly disagree" to 5 "I strongly agree".
R3 – The MBSF is considered very useful but not fully ready for implementation
29
>> Average score of usefulness of MBSF is 4.5. >> Meaning between 4. “good” and 5. “very good” >> Government and business attribute similar scores >> Average score of readiness of MBSF for implementation is 3.3. >> Meaning 3. “neutral”
1,0 1,5 2,0 2,5 3,0 3,5 4,0 4,5 5,0
The MBSF regulation is ready forimplementation
The MBSF regulation is a useful tool for theMozambican biofuel industry
Evaluation: the 15 participants are convinced of the value of the MBSF but not yet about whether it is ready for
implementation
Scores range from 1 "I strongly disagree" to 5 "I strongly agree".
R3 – All participants were happy with the work done in the pilot
30
>> Average score is 4.1 >> Meaning 4. “good”
1,0 1,5 2,0 2,5 3,0 3,5 4,0 4,5 5,0
The pilot helped to understand how the MBSFcan be improved
The pilot helped to understand how the MBSFwill work in practice
The field visits were well prepared andorganised
The pilot was well prepared and organised
The communication during the pilot was ofgood quality and of the right frequency
The documents produced in the pilot wereuseful
Evaluation: the 15 participants are happy about the pilot
Average scoree= 4,1 out of 5,0. Scores range from 1 "I strongly disagree" to 5 "I strongly agree".
R3 – Participants provided suggestions on biofuel sector development
For example>> Q31 Do you have recommendations on how to further the development of the biofuel sector in Mozambique? 1. In the case of cassava, companies should produce the raw material in their fields 2. Improvement of regulation 3. More disclosure and in all sectors 4. Making extensive approach to citizens in education and in rural areas 5. Government entities should support the promotion of biofuel practices and grant
tax benefits to companies 6. Sensitize the local level about the use and benefits 7. Review which crops can be used as a biofuel crop 8. Decrease complications of legislation. Keep things simple and clear. Disclose law 9. Greater co-operation between government and producers for more clarity on
regulations 10. The biofuel sector in Mozambique should enhance the integration of the use of
biofuels through having centralized processing and storage units, clear biofuel policies and quality standards to ensure its acceptance in the market
31
R3 – Participants provided suggestions for the government sector
For example>> Q32 Do you have specific recommendations in this perspective for the government sector? 1. Educate and train technicians on the MBSF regulation 2. Coordinate the work to ensure best possible legislation 3. Strive to coordinate with biofuel companies 4. Encourage the production of biofuels in the national territory to combat
destruction through unsustainable tree cutting for charcoal 5. Secure areas for food production, ensure food security and sustainable development 6. Try to harmonize regulations and ensure that they are applicable in the field 7. Ensure periodic multidisciplinary monitoring 8. Strive for participation of other institutions such as the Ministry of Labour 9. Create exceptions to certain rules. Disclose legislation connected with the whole
process of the biofuels industry 10. Include cassava as a biofuel crop 11. Provide assistance in developing rail transport, clear biofuel policies, price
mechanisms and storage at ports
32
R3 – Participants provided suggestions for the private sector
For example>> Q33 Do you have specific recommendations in this perspective for the private sector? 1. Employ trained Mozambicans in existing areas. For example agronomists 2. The private sector has to show evidence of 100% in the process 3. Ensure the use of clean technologies, avoid food insecurity 4. Keep interconnected and participative on government policies. Continue to open
discussions based on analysis of government legislation 5. Collect evidence that demonstrates that they comply with applicable legislation.
Ask for available tax benefits 6. Involve more communities, always work in partnership with local governments 7. Understand perfectly the Mozambican biofuel policy and its price mechanisms
33
R3 – Participants provided suggestions for third parties
For example>> Q34 Do you have specific recommendations in this perspective for third parties (consultants, certification bodies, others) 1. Know and have the domestic legislation 2. Consultants have to work with depth and co-ordinate with certification bodies in
order to discover and resolve the bottlenecks 3. Should continue to work with communities and producers of biofuels to ensure a
correct implementation 4. Be serious in investigations and offer recommendations... 5. Know the complexity of the country and try to link approaches to top management 6. Use the framework 7. Easing the legislative process, search for solutions 8. Certification bodies and consultations should be open minded, flexible and realistic
when assesing projects 9. Ensure promotion of investment in biofuel sector
34
R3 – Participants provided suggestions for follow-up activities and next steps
For example>> Q44 Do you have suggestions for follow-up work that needs to be done? 1. Integrate representatives of the beneficiaries in the team to reinforce the evidence 2. Disclosure and monitoring of the regulation 3. Distribution of the material 4. Monitoring and frequent consultations, schedule periodic monitoring of companies 5. Providing periodic reports (monthly) to structures in charge of permit in districts
and provinces 6. The monitoring should start with information at provincial level and then national 7. May-be help companies implement all recommendations 8. Review progress in 6 months 9. Follow up on evidence documents so that pilot projects may reach up to 100% full
evidence
35
R3 – The government delegation suggested practical MBSF improvements
For example>> 1. Typify the documentation required for each principle 2. Specify the competences of the central organ (CIB) and the provincial government 3. Revise Art 8… responsible for the CIB... coordinating with the provincial government 4. Revise Art 9... fitting the CIB in co-ordination with the government provincial... 5. Provide the form of Annex 2 information necessary... 6. Improve Art 13 with regard to the sanctions... typify what corresponds to warnings,
fines... as a function of the nature of principle, criterion and indicator. 7. Regarding Art 14b refers to analysts and technical meeting of the IWC. 8. Revise Art 8 regarding the level of compliance with quantitative and qualitative. 9. Classify the articles... 10. Revise verifiers to avoid repetition 11. Clarify the issue for the cut of trees for project investment. Need licenses or not. 12. Clarify the issue regarding the need to have a license for use of groundwater... 13. Clarify how to assess GHG balance sheet, energy balance, energetic efficiency. 14. Break down compliance/evidence in the regulation as in the tool 15. Clarify responsibility per principle (P5 P6 joint responsibility CEPAGRI DNTF)
36
R4 – A seminar will ensure sharing of results with Mozambican stakeholders
> Date and timing 31 October , 13H-17H
> Location: Beira
> Organisor: CIB represented by DNER
> Target public: National biofuel sector. Target of 50 persons: staff of relevant national and provincial directorates, biofuel companies, interested NGOs
> Seminar objectives: 1. Sharing results of MBSF pilot 2. Sharing lessons learned of MBSF pilot 3. Sharing the new version of the MBSF 4. Preparing the implementation of the MBSF
> Seminar language: PT. Simultaneous translation to EN
> Draft programme: PfI proposes to DNER, CEPAGRI and AGNL
> Draft invitation list: DNER and CEPAGRI propose
> Sending of invitations: DNER
> Seminar logistics: CEPAGRI (transport, accomodation, overnight stays, simultaneous translation) with PfI
> Participant registration: DNER 37
Biofuel sector developments in Mozambique: looking backwards, looking forwards
38
Years 2007-2008
2009-2010
2011-2012 2013 2014 >>
Biofuel private sector
• Massive land requests
• Micro scale test plots
• Land preparation
• Few pioneers
• Small scale test plots + larger plots planted
• Embryonic sector
• Few pioneers
• Few productive companies, many pre-productive
• Small scale • Few companies
• Productive companies?
• Bigger scale? • More companies?
Biofuel policy • Work on policy starts
• Work on zoning starts
• Biofuel policy and strategy
• Zoning continued
• Biofuel blending regulation
• CIB decree
• Price mechanism? • Biofuel standards? • Logistics studies?
Sustainability framework
• Work on framework starts
• Draft regulation
• Pilot • Decree biofuels sustainability assessment?
• Assisted implementation (dedicated tool, website, training)?
Muito obrigado !
Colophon
During the MBSF pilot, companies, government and Partners for Innovation worked with the MBSF so test how assessing compliance against the MBSF can be done in practice.
The work reported in this document was part of the pilot and should not be considered a criticism of any of the organizations involved.
Although this document was developed with the greatest possible care, Partners for Innovation does not accept liability for possible errors.
The authors welcome any feedback and suggestions for improvement.
39
Peter Vissers, Managing Director
+31 (6) 4260 9354
+258 (84) 0229 923
João Chidamoio, Senior Biofuel Expert
+258 (84) 6229 476
+258 (82) 8786 300
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