In order to address concerns about food security, the Biofuels Regulatory Framework (SA Department of Energy,
2014) currently excludes maize (a staple food in SA) and sugarcane (because of irrigation requirements) from biofuel
crops, despite arguments from industry that these crops are most productive for biofuels and currently produced in SA
(Business Day, 2014; Letete and Von Blottnitz, 2012; South Africa Civil Society Information Service 2012); see also Fig. 9. Instead, the first phase will consider only grain sorghum (for bio-ethanol) and soybeans (for bio-diesel). Licensed producers will also have to conform to other requirements in order to be granted the subsidy, such as 25% ownership by Black South Africans, a minimum of 10% of feedstocks being sourced from Black smallholder farmers, and, if irrigation is required, a detailed motivation for how this will be done ‘without negatively impacting the country’s constrained water resources’. A Water Research Commission (WRC) scoping study on water use of biofuel crops in SA found that soybean production (mainly in the eastern part of the country) would, for the most part, not use more water (i.e. reduce runoff) than the dominant indigenous vegetation (‘veld type’) (Jewitt et al., 2009).