Indirect Land Use Model Undergoes Peer Review

Rep. Collin Peterson says the outcome confirms need to prevent EPA from implementing indirect land use theories.

The Environmental Protection Agency released four peer reviews, two on Indirect Land Use Change modeling and the Lifecycle Greenhouse Gas Analysis, included as part of the Renewable Fuels Standard (RFS 2) Proposed Rule on August 7.

In May, EPA Administrator Lisa Jackson announced the lifecycle analysis would be peer reviewed when the agency proposed its overall strategy for increasing the supply of renewable fuels.

Researchers in the Center for Agricultural and Rural Development and the Food and Agricultural Policy Research Institute at Iowa State University have worked for the last 18 months with EPA staff and other academic modelers at Texas A&M University and Purdue University to estimate the impacts on agriculture from expanded biofuels. EPA staff then used the results of this analysis in their life cycle assessment of biofuels.

It was this model that was peer reviewed.

Because model predictions cannot be refuted by past data, the credibility of models relies on submitting the models and results to peer review, being transparent about model assumptions and parameters, and putting in place a process by which the models reflect the latest knowledge about agricultural and food systems, wrote Bruce Babcock, CARD Director in his paper Measuring Unmeasurable Land-Use Changes from Biofuels.

The ethanol community continues to refute the FAPRI model, saying it can't be replicated by stakeholders. Babcock explained that the law required EPA to measure indirect land use impact both domestically and internationally. However, there wasn't a model at the time that was specifically designed for looking at land use changes.

Babcock said, "The state of the models from my perspective aren't reliable enough to make obsolete huge investments. But EPA was caught between a rock and a hard place and are doing the best possible to abide by the law."

House Agriculture Committee Chairman Collin Peterson, D-Minn., said the review panel expressed concern about using incomplete and unreliable models to indirect land use changes and indicated they didn't have enough time to review this "convoluted and complicated proposal."

The FAPRI model is the same basic modeling system that has been used for policy analysis to track trade agreements and the international impact of farm bill legislation, Babcock said.

If you look at pure economics, if you increase biofuels production, the price of corn would go up. This will in turn increase production around the world because prices provide an incentive to increase corn production, Babcock said. 

"All land use changes overseas is caused by price," he said. Ethanol supporters say extra land isn't needed domestically or internationally because yields are increasing.

Production gains are harder to quantify and is more difficult to attribute to the increased use of biofuels, Babcock said. EPA would need to be able to quantify that the yield improvements were done because of a change in management such as increased fertilizer use or technology adoption such as improved genetics to show that yield gains are a result of increased biofuels production.

Questionable reviewers

Ethanol groups said the agency "stacked the deck against biofuels" in its peer review process. The Renewable Fuels Association (RFA) criticized EPA for selecting "peers" who have been vocal opponents of biofuels or who have released studies later called into question, including environmental lawyer Timothy Searchinger and Dr. Joseph Fargione.

"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."

Legislative fixes

Tom Buis, CEO of Growth Energy, called on Congress to fix the "flawed provision" in the 2007 Energy Independence and Security Act.

"We need to stop this nonsense. This is the most bizarre concept I have ever seen. EPA's peer review proves that too much uncertainty about the economic modeling, data and science exists to allow this to ever become regulation. Even the peer review committee could not agree. That's why we need Congress to act today to pass legislation either repealing this flawed concept, or adopting the provision recently passed by the House of Representatives to require a thorough review by the National Academy of Science," Buis said.

Peterson also voiced concern that there is no evidence that USDA 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," Peterson said.

Both RFA and Growth Energy criticized the timing of the release coming right as Congress left for a month long August recess.

"It is time for Congress to weigh in immediately," Buis said. "Just as this provision was stuck into the law in the middle of the night without public debate, now EPA is releasing its flawed review when Congress is headed home for the month of August."

For more information on the peer review visit

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