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Best Available Science?

April 3, 2009
Yesterday, the Scientific Committee on Problems of the Environment (SCOPE) released a report, “Biofuels: Environmental Consequences and Interactions with Changing Land Use,” based on the proceedings of its International Biofuels Project Rapid Assessment.

The Environmental Working Group immediately praised the report, claiming that it “confirms that corn-based ethanol is a dead end.” (I recommend reading this response to EWG by Biofuels Digest’s Jim Lane.)

Far from that confirmation, the report’s recommendations recognize that whether the maximum environmental benefit of biofuels is achieved depends on how they’re produced, and that “many of the adverse effects of biofuels on the environment could be reduced by using best agricultural practices.” In fact there are 17 papers included in the report, drawing a range of conclusions about the benefits or dangers of biofuels.

Still, the executive summary cites a number of premises regarding biofuels that environmental groups now consider articles of faith:

The rapidly growing production of biofuels requires additional cropland. In some cases, this additional land comes from agricultural land previously used to grow food or feed crops. In a hungry world, these diverted crops must be made up elsewhere, thus driving land conversion– perhaps in different countries and on different continents – to compensate for the loss of food-crop production.”

I’ve heard these premises asserted as fact too many times now, yet no one has yet publicly demonstrated direct evidence of them. Within academic papers, it has become customary to footnote the paper by Searchinger et al in Science last February, but even that paper cited the same assumptions.

It is certainly a reasonable hypothesis to test whether crop production throughout the world has expanded into ecologically sensitive carbon sinks as a result of the U.S.’ inability to meet its share of increased worldwide demand for food and feed. It is also reasonable to test the alternative hypothesis that increases in crop productivity are able to meet the incremental increases in biofuel production under the RFS. Either way, it would likely be most effective to work for an international accord to directly protect ecologically sensitive carbon sinks, but that would take more work.

It should also be noted that production of agricultural commodities was shifting to other countries prior to the 2005 and 2007 laws. In point of fact, Argentina, Australia, Brazil, Canada, Costa Rica, the European Communities, Guatemala, India, Nicaragua, Mexico, Thailand and Uruguay have all joined a WTO dispute against the United States aimed at expanding in most cases their own agricultural production.

Iowa State University’s Center for Agricultural and Rural Development noted in response to that WTO case:

Farmers base their decisions about what and how much to plant on numerous factors, including rotation considerations, production costs, expected market prices, availability of crop insurance, and expected benefits from farm programs. The complicated nature of these decisions makes it quite difficult to determine if U.S. farm programs for crops other than cotton are vulnerable to a WTO case against them on the basis of price suppression. The role that these programs play in farmers' planting decisions varies across crops, regions, and crop years. Simple "rules of thumb" that use total payment levels as a guide or the belief that the programs work as a cheap food policy are inadequate measures of the impacts of farm payments on U.S. supply and international commodity prices.”

Those conclusions are applicable to the current debate on indirect land use change.

But now the assumptions cited by environmentalists are set to be enshrined within California’s Low Carbon Fuel Standard, despite the fact that California admits the available evidence contradicts the premises.

Nathanael Greene of the Natural Resources Defense Council considers the California law and the EPA’s expected rule on the RFS, which utilizes similar modeling, to be the best available approach:

In order to develop a full lifecycle accounting protocol that includes emissions from indirect land-use change, both regulators are relying on economic models. They use these models to look at the world first without the biofuels and then with them; the change in pollution is assigned to the biofuels. While the models are complex, both agencies have relied on the best peer-reviewed science and economics and will update their rules regularly over time."

Jim Lane of Biofuels Digest has provided a very cogent and much needed analysis of the methodology being used to "measure" the indirect land use change carbon emissions attributed to biofuels:

In short, we’re arguing about whether the models make for a good forecast. A problem is that we haven’t backcast -- that is, checked the predictions of the model against known outcomes in the past to see if the predictions were accurate."

Another problematic aspect of the use of general equilibrium models in lifecycle analysis is that they require the assumptions that the environmentalists cite as articles of faith. The models are therefore incapable of testing the assumptions as hypotheses. General equilibrium models, by definition, must assume a point of equilibrium and then assume a shock to the system. They are properly used to assess the risks of a new policy or program that is expected to have an economic impact on markets. But the calculated outcome of the modeling, the new predicted equilibrium, is not an actual measurement.

So these models do not look at the world without biofuels and the world with biofuels to compare them. In fact, they make calculations that come directly from their starting assumptions. To mistake the calculations for conclusions is circular logic. It is not the best available science – it isn’t science at all.