The Renewable Fuels Association (RFA) recently asserted that the Environmental Protection Agency (EPA) stacked the deck against biofuels in its process to “peer review” the agency’s indirect land use change analysis (ILUC) conducted for the Renewable Fuel Standard (RFS2) proposed rule.
The EPA recently released the much anticipated peer reviews of its lifecycle greenhouse gas (GHG) analysis and ILUC modeling conducted for the RFS2 proposed rule. Among the “peer” reviewers are several noted anti-ethanol and anti-agriculture activists, including environmental lawyer Timothy Searchinger. The politically motivated positions of Searchinger, Joseph Fargione and others with respect to ILUC have repeatedly been called into question.
“EPA has asked the foxes to guard the hen house on this issue,” says RFA President Bob Dinneen. “By adding lawyers and advocates to a scientific review panel, EPA bureaucrats have made a mockery of the administration’s commitment to sound science. These reviews absolutely cannot be viewed as objective or unbiased. Many of these reviewers have repeatedly and openly demonstrated unabashed and politically-motivated biases against biofuels in the past, which immediately casts a long shadow of doubt over the legitimacy of EPA’s peer review process.”
In a letter to EPA Administrator Lisa Jackson earlier this week, the RFA again noted that due to the nature of the models used, stakeholders simply cannot validate EPA’s lifecycle analysis, particularly as it relates to ILUC.
“How can a peer reviewer fairly validate a method that simply cannot be reproduced by anyone?” Dinneen asks. “Did any of these reviewers attempt to run the FAPRI model to corroborate EPA’s results? I doubt it. If they had, they would have quickly discovered that no one outside of the small group of modelers who performed the analysis for EPA can actually run the model in the same way that EPA did. The release of these reviews doesn’t change the fact that EPA’s indirect land use change analysis is ultimately not reproducible by stakeholders and therefore inappropriate for this use.”
The inclusion of activists like Searchinger and Fargione is particularly troubling. Their speculation on the impacts of biofuel production on international land use decisions in foreign nations drew a harsh and immediate response from many in the scientific community when their articles were released in the February 2008 edition of Science.
For instance, Michael Wang, a fellow peer reviewer, scientist at the Department of Energy’s Argonne National Laboratory and developer of the GREET model Searchinger mutated to develop his polemic, questioned Searchinger's findings. According to Wang’s response to Searchinger’s paper:
“While scientific assessment of land use change issues is urgently needed in order to design policies that prevent unintended consequences from biofuel production, conclusions regarding the GHG emissions effects of biofuels based on speculative, limited land use change modeling may misguide biofuel policy development.”
Much of the list of “peer” reviewers reads like a who’s who of ethanol and agriculture detractors. Beyond Searchinger and Fargione, several other vocal ethanol opponents with clear conflicts of interest were asked to “peer review” the EPA work. Among them are two researchers who were co-authors on Searchinger’s controversial and discredited 2008 Science paper on ILUC; staffers from two environmental activist groups; and several academics with an ideological axe to grind against production agriculture and contemporary biofuels. Several of these academics have served as paid consultants to environmental groups with anti-ethanol and anti-agriculture agendas.
“This is a perversion of what the peer review process is supposed to achieve,” said Dinneen. “It’s little wonder EPA waited until Congress left town for the August recess to release these reviews. EPA cannot feel comfortable that they are getting complete and unbiased feedback based on the panel they have assembled here.”