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Brazilian Coalition’s Proposals for a National Policy on Biodiversity Economy Development

To the Senate Environment Committee:

The drive to scale up Bioeconomy has direct link to several national efforts towards sustainable development: food security, job creation and socio-economic development, and contribute to climate change mitigation.

The Brazilian Coalition on Climate, Forests and Agriculture, a movement comprised of more than 350 representatives from agribusiness, industry, civil society, the financial sector, and the academia, as a group with a great diversity of organizations and companies engaged in agriculture and forestry, adopts a comprehensive definition of the Bioeconomy concept, linked to the Brazilian identity and vocation.

We advocate that in Brazil, Bioeconomy should promote responsible use of biodiversity, development of sustainable agricultural and forestry systems, protection and restoration of native vegetation, socioeconomic integration of traditional communities and family farmers, and income generation for Brazil’s rural and forestry sector. Indeed, the Bioeconomy proposed by the Coalition explores the interface between agriculture, livestock, and forestry.

The public hearing “Dialogues for a national bioeconomy strategy in Brazil”, held on June 20, 2023, was organized by the Senate Environment Committee, and chaired by Senator Leila Barros.

The hearing was held in conjunction with the Brazilian Coalition’s Bioeconomy Task Force and the Federal Senate’s Environment Committee and was part of the Virada Parlamentar Sustentável. The focus of the discussion was on the work of the Bioeconomy WG from the Ecological Generation Forum, held in 2022 by the Senate Environment Commission, and which led to the drafting of proposed laws, among them Bill 1855/22 for the National Policy on Biodiversity Economy Development (PNDEB, in Portuguese acronym).

The movement acknowledges the importance of the bill that seeks to establish the National Policy on Biodiversity Economy Development (PNDEB). We consider that this proposal is a relevant instrument to help promote the Bioeconomy stemming from forestry and agroforestry systems in Brazil, at different scales and including priority stakeholders such as traditional peoples and communities and family farmers, among other important players of the chains.

However, we emphasize the need for a specific focus on the sociobiodiversity chains, the bill’s priority target. We believe that the bill’s goals should be more focused, being centered on sociobiodiversity chains, recognizing that there are already several policies, initiatives and efforts in the different spheres of government around the extensive subject of Bioeconomy with special attention to the Law of Access to Genetic Heritage, Protection and Access to Associated Traditional Knowledge and Benefit Sharing (Law No. 13,123/2015) and its regulating decree (Decree No. 8,772/2016), which has a central role both for the Bioeconomy in the biotechnological and bioecological vision. Therefore, we recommend the exclusion of Art. 2, item II, according to the draft attached.

On one hand, it is essential to avoid mixing the subjects and ensure a clear focus on adding value around socio-biodiversity and, on the other hand, to ensure proper integration of governance on the matter among the federal government’s connections. It is key to ensure a straightforward structure, including responsibilities attribution and efficient coordination. Since the bill establishes goals and general guidelines for the National Policy on Biodiversity Economy Development, further regulation by the Federal Government will be necessary to define how it will be implemented. It will be necessary to address, for instance, PNDEB’s governance structure (art. 6, 7 and 8) for the execution of the outlined instruments (art. 4 of the Bill).

Although policy execution is in the hands of the Executive Branch, it is necessary to clearly indicate where the policy would be operationalized. We suggest that the Ministry of Agrarian Development (MDA) must be hold accountable for implementation, with an inter-ministerial committee, like the Amazon Fund, to ensure effective coordination among the stakeholders.

We also emphasize the importance of linking resources to the proposal. Amending laws, such as those that created the National Environmental Fund and the North, Northeast and Central-West Constitutional Financing Funds, is an important step. However, it is necessary to evaluate if these amendments are enough or if it would be necessary to include a budget line for the multi-annual plan. One must also consider what the Brazilian Fiscal Responsibility Law (LRF) stipulates, which requires that any bill that implies an increase in expenses must be accompanied by estimates of the budgetary and financial impact, especially if they are expenses of a continuous nature, in which case it is necessary to demonstrate the origin of the resources for its funding.

We also note that some terms and concepts in the proposal need to be refined. For example, instead of “recipients”, we suggest the use of the term “target audience” to refer to the stakeholders involved. In addition, we advise against the use of “biodiversity assets” as a guarantee for access to credit since there is no clear metrics and methodology for its measurement.

Lastly, we stress the importance of including restoration as part of the Bioeconomy proposal. The restoration of degraded ecosystems is essential to promote biodiversity conservation and recovery of essential ecosystem services.

The Brazilian Coalition on Climate, Forests and Agriculture reasserts its commitment to contribute in the debates and improvement of the Bioeconomy agenda in Brazil, reinforcing our vision to contribute to the creation of an inclusive, comprehensive and simplifying National Bioeconomy Policy, which nurtures opportunities, encourages innovation and avoids regulatory restrictions, while seeking synergies with similar initiatives under discussion in the country.

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