EPA Releases Peer Review of Indirect Land Use Analysis

August 9, 2009 07:00 PM

Pro Farmer Editors

The Environmental Protection Agency (EPA) has released the peer review conducted on the renewable fuel standards lifecycle greenhouse gas analysis and indirect land use change (ILUC) modeling EPA conducted for the Renewable Fuels Standard-2 (RFS2) proposed rule. EPA noted the "lifecycle analysis would be peer reviewed when the agency proposed its overall strategy for increasing the supply of renewable fuels."

However, in examining the various responses the peer reviewers offered, they raised several questions about the accuracy of the results of the various models used, noting cases where assumptions may underestimate or overestimate impacts.

Many of the peer reviewer questions centered on issues relative to the use of the Forestry and Agriculture Sector Optimization Model (FASOM) and the Food and Agricultural Policy Research Institute (FAPRI) models. The analysis also used the Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) model to quantify the emissions factors associated with different steps of the production and use of various fuel types.

While the private contractor who selected the individuals to conduct the peer review did ask questions, etc., relative to any conflict of interest issues, they noted that "experts with a stake in the outcome – and therefore a conflict or an appearance issue -- may be some of the most knowledgeable and up-to-date experts because they have concrete reasons to maintain their expertise," and that these experts may be used as peer reviewers if COI or the appearance of the lack of impartiality is disclosed.

However, upon review of each form, the contractor and EPA determined that there were no direct and substantial COI or appearance of impartiality issues that would have prevented a peer reviewer's comments from being considered by EPA.

Here's a link to read the lengthy sets of peer-review documents on this topic.

But that explanation didn't set well with the Renewable Fuels Association (RFA), who released statement raising a question whether EPA had "stacked the deck" against biofuels with the process of selecting the peer review group. The specifically pointed out that one of the peer reviewers was environmental lawyer Timothy Searchinger, who they labeled "an anit-agriculture activist."

"EPA has asked the foxes to guard the hen house on this issue," said 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."

Further, RFA noted, "Much of the list of 'peer' reviewers reads like a Who's Who of ethanol and agriculture detractors. ...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."

And some in Washington who have been skeptical about indirect land use change reacted negatively to the EPA peer review release. House Ag Committee Chairman Collin Peterson (D-Minn.) released the following:

"The EPA peer review panel reaffirmed many of the concerns I have about the EPA's proposed rule and rulemaking process for the Renewable Fuel Standard (RFS2). The panel expressed concern about using these incomplete and unreliable models to measure indirect land use changes and indicated that they didn't have enough time to review this convoluted and complicated proposal. I am also concerned that there is no evidence that the U.S. Department of Agriculture or any other Federal agencies with expertise on these issues were included in the peer review process. This is exactly why the House of Representatives voted in the climate change bill to limit EPA's ability to implement international indirect land use provisions in the RFS2."

Ironically, on the heels of this EPA release, we note the following which came from Iowa State University. They highlighted work done by Iowa State University's Don Hofstrand on corn ethanol's greenhouse gas (GHG) emissions.

Hofstrand's work shoed 50% comes from crop production with fertilizer a major source, and 50% comes from biorefinery operations with natural gas and electricity accounting for 90% of these emissions. Hofstrand calculates that corn ethanol currently provides "a 54% reduction in GHG emissions as compared to gasoline." He sees this lead lengthening as corn yields increase and fertilizer management practices improve. He also forecasts steady improvement on the biorefinery side.

Along with the prospect of powering biorefineries with biofuels rather than fossil fuels, Hofstrand points out that "Various ways of reducing the amount of thermal heat for ethanol production are being researched." As well, he sees "the potential for reduced water use and the development of higher value co-products," all adding up to more energy efficient operations which pump out more ethanol with lower GHG emissions.

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