Best Available Science?

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.

Environmental Groups Pressure EPA to Calculate Indirect Emissions

The latest salvos on the EPA’s rulemaking process for the Renewable Fuel Standard come from six major environmental groupsthe Environmental Defense Fund, National Wildlife Federation, Natural Resources Defense Council, Friends of the Earth, Union of Concerned Scientists, and Environmental Working Group – and academics at the University of California Berkeley.

In their letter to EPA Administrator Stephen Johnson, the environmental groups argue that delaying conclusions about which biofuels make the grade under the RFS until after the EPA has solicited comments on the rule “would encourage ventures that increase global warming pollution and will fail once the lifecycle accounting accurately and completely addresses the impact of land use changes.”

I have to disagree. Deciding which biofuels make the grade and which don’t before lifecycle accounting accurately addresses land use change risks discouraging investment in projects that might eventually have a beneficial impact on climate change emissions.

The groups further say, “We think that the inclusion of indirect effects will illustrate which second-generation feedstocks incur the least indirect land use changes.” However, since there are few second-generation feedstocks actually in production, the analysis of lifecycle emissions will be based on small-scale data. The indirect land use change emissions, particularly on a worldwide scale, will be purely hypothetical, since no large-scale markets currently exist for second-generation feedstocks. In fact, one of the stumbling blocks for the industry is the need to create the markets for harvesting second-generation feedstocks.

To decide which of these feedstocks “incur the least indirect land use changes” and to try presumptively to “distinguish promising approaches from dead ends” before data is gathered or the model proposed by the EPA is fully developed will undercut investment in second generation biofuels before they get off the ground.

The EPA’s “rigorous rule-making process that has drawn on the best available science,” as these groups put it, runs a great risk of appearing arbitrary by announcing premature conclusions about the land use change emissions calculation for biofuels.

Arguments about the food price impact of biofuels, some put forward by noted academics using the best available science, have ultimately been contradicted by evidence throughout the past year. While crop prices that reached highs during the summer and food prices that spurred riots in some corners of the world seemed to bear out the worst scenario put forward by respected researchers such as C. Ford Runge, the collapse of food prices in the past few months tends to support others who said that the price of oil was the main driver. See an earlier post for other arguments.

In a separate letter to Johnson, the group of academic experts led by University of California Berkeley’s Michael O’Hare put forward a series of arguments to refute the original letter from Bruce Dale et al. The Berkeley et al. academics sum up their argument so:

That some land will be brought from natural conditions into cultivation, with accompanying rapid carbon emissions from the existing vegetation, when ethanol demand is added to whatever other corn the world market would otherwise use, is an inference from absolutely foundational and uncontroverted elementary principles of human behavior, such as the law of demand. Exactly how large the effect is requires sophisticated predictive models and will never be as precise as measuring the specific gravity of ethanol, but to act as though the effect is nil is simply obscurantist and unscientific. No principle of law or regulatory practice or common sense dictates that the state must regard any uncertain value as zero.”

The problem with this is that there are other influences on land being “brought from natural conditions into cultivation” besides the demand for corn to produce biofuels, and current predictive models are not sophisticated enough to either measure the effect or to separate the various influences. But there is a principle of regulatory practice to point out. The regulatory action must provide the relief sought. Regulation of biofuels in the way sought by environmental groups ought to reduce greenhouse gas emissions from native land brought into cultivation. Since the EPA is not regulating deforestation around the world, there is little chance that will happen.

Robert C. Brown, director of the Bioeconomy Institute at Iowa State University, has a very cogent dissection of the environmentalists’ arguments:

People in the developing world are finding it profitable to expand agriculture in their own countries rather than depend upon U.S. farmers to feed them. In some progressive circles, this might sound like a good thing – what we in the United States admiringly refer to as self-reliance.
“There is no scientific evidence indicating that deforestation is driven by biofuels production. Whereas the world has lost 500 million acres of rain forest in the past 10 years, the U.S. biofuels industry has diverted less than 20 million acres to ethanol production. Something else is responsible for the epidemic of deforestation.”

EPA Gets Input on Sustainable Biofuels

On Monday Oct. 27, the EPA’s Science Advisory Board held a workshop in Washington on “Looking to the Future.” The stated purpose of the workshop was “to stimulate SAB thinking about priorities for meeting critical environmental problems with an integrated approach to interdisciplinary science and research” and gather data on the net environmental implications of biofuels. A number of experts on biofuels and agriculture gave SAB presentations on land use change and other possible climate change emissions from biofuel production.
In their presentation, Dr. Bruce Dale of Michigan State University and Dr. Lee Lynd of Dartmouth noted that in calculating emissions from land use in a life cycle analysis, “a large range of outcomes is possible depending on whether or not land conversion is approached with the intent to minimize carbon debts.” In a study, they look at the variation in outcomes to an indirect land use change analysis such as Searchinger’s. If the timber from cleared rainforests is used for furniture or paper instead of burned, as Searchinger assumed, or if land is managed with conservation tillage practices rather than conventional plow tillage, then “‘carbon debt’ from forest conversion is greatly reduced and may well be negative for some real systems,” Lynd and Dale told the SAB. Further, “Production of biofuel from prairie grass on abandoned or marginal cropland repays the conversion carbon debt in less than a year with large carbon savings thereafter.”
This is a point that David Tilman of the University of Minnesota, who also testified at the SAB meeting, would agree on, since he said, “Whether or not a given biofuel offers carbon savings and other environmental benefits relative to a fossil fuel depends on how the biomass crop is produced.”
Outside of this official comment process, a number of groups have been petitioning EPA Administrator Johnson to take a different course on the rulemaking process. First, Bruce Dale and other academics sent a letter to Johnson asking him to delay inclusion of indirect land use in the rule for biofuels until better models could be constructed. Recently, the Clean Air Task Force, Environmental Working Group Action Fund, and Friends of the Earth sent a letter to Johnson responding to the Dale letter (See Environmental Groups Response Letter to EPA Administrator). Their argument: “Growing crops for energy in addition to food and feed requires the cultivation of additional land.” This is precisely what remains unproven in the analyses.
The Biotechnology Industry Organization also sent a letter to EPA Administrator Johnson proposing that the EPA reveal its methodology for including indirect land use change so that the proposed rule’s comment period could be used for refining the model before any conclusions are drawn about the impacts of specific biofuels (See BIO Letter to EPA Administrator Johnson).