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The science of economically-mediated indirect effects from the
production of biofuels and fossil fuels is in its infancy. The
study by Searchinger et al. (Science 2008) and other related works
are the first attempts at defining significant indirect effects. In
this case, deforestation and grassland conversion are only two of
many indirect effects that alter global net greenhouse gas
emissions from fuel production. In one of the few works published
in a peer-review journal on this subject, professors Adam J. Liska
and Richard K. Perrin at the University of Nebraska review the
science of indirect effects of biofuel production in an article
entitled “Indirect Land Use Emissions in the Life Cycle of
Biofuels: Regulations vs. Science” in press in the journal
Biofuels, Bioproducts, and Biorefining.

In addition to investigating indirect deforestation and grassland
conversion alone, a more comprehensive assessment of the total GHG
emissions implications of substituting biofuels for petroleum needs
to be completed before indirect effects can be accurately
determined. Our review found that indirect emissions from livestock
and military security are particularly important, and deserve
further research, in addition to numerous other factors. Attached
please find a pdf copy of the article for review. The identified
additional indirect emissions must be analyzed and included if
these types of effects are to be regulated. By only accounting for
land use change due to biofuels and not other indirect effects for
both biofuels and petroleum, this regulation would be employing an
arbitrary and biased standard.