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Comment 14 for Low Carbon Fuel Standard (lcfs09) - 15-1.

First NameJohn
Last NameMatthews
Email Addressjohn.mathews@mgsm.edu.au
AffiliationMacquarie University (Australia)
SubjectAnalysis of Biofuels Indirect Land Use Effects Finds the Science Lacking
Comment
Analysis of Biofuels Indirect Land Use Effects Finds the Science
Lacking
Too Diffuse and Subject To Too Many Arbitrary Assumptions To Be
Useful for Rule-making.

– Lack of transparency and scientific integrity in Searchinger et
al. questioned;
- Searchinger et al. paper described as more ideology than science
and seeking to put biofuels in worst possible light;
- Alternative approaches likely to be more fruitful in genuinely
evaluating effects of biofuels grown around the world.

A scholarly analysis of the keystone of indirect land use study –
Searchinger et al. – found the science fell far short of acceptable
scientific standards. Professor John Mathews and Dr. Hao Tan,
researchers from Macquarie University in Sydney, Australia,
undertook an exhaustive analysis of Searchinger et al. which
revealed that the framework used was inappropriate in that it
started with assumptions as to diversion of grain to ethanol
production in the U.S. but then extrapolated these to parts of the
world, such as sugarcane growing in Brazil, which are actually
(much) more bio-efficient. Mssrs. Mathews and Tan’s analysis
concluded that Searchinger et al. failed sound scientific standards
on many fronts and that government agencies relying on Searchinger
et al. findings for evaluating biofuels would be better served by
utilizing other controls.

    “Indirect land use change effects are too diffuse and subject
to too many arbitrary assumptions to be useful for rule-making,”
stated Professor Mathews. “The use of direct and controllable
measures such as building statements of origin or biofuels into the
contracts that regulate the sale of such commodities would secure
better results.”

    The issue is where to draw the boundary for life cycle
analysis and how to address ILUC effects within the boundary.
Non-industry experts are concerned that this is taking regulatory
action too far, and the science underpinning such actions,
including the ILUC calculations of authors such as Searchinger et
al., cannot stand the scientific weight being placed upon them.

    The Mathews and Tan analysis states that the real target of
the Searchinger et al. paper would appear to be the model of U.S.
ethanol production developed by the Argonne National Laboratory in
the U.S. Researchers at Argonne have developed a model for biofuels
production and consumption in the U.S. that takes full life cycle
analysis issues into consideration as well as some attention to
land use changes. But the Argonne work does not extend to indirect
land use changes, which are considered too uncertain to be modeled
– and so it has come in for much criticism from Searchinger et al.
as well as others.

    “If you wished to put U.S. ethanol production in the worst
possible light, assuming the worst possible set of production
conditions guaranteed to give the worst possible set of indirect
land use effects, then the assumptions would not be far from those
actually presented in the Searchinger et al. paper,” commented Dr.
Hao Tan. “Frankly, better science upon which to base rule-making is
available today.”

    The Mathews and Tan analysis identified six areas in which
Searchinger et al. fell short:

        * Direct plantings of biofuels crops around the world are
ignored, and instead a spike in U.S. corn-based ethanol is
considered a trigger;
        * The U.S. spike is met exclusively by growing corn – but
other ways of meeting the U.S. spike, all involving fewer GHG
emissions, are ignored;
        * The U.S. spike met entirely within the U.S. – without
regard to trade (such as half of the spike being met by Brazilian
sugarcane and imported into the U.S.);
        * The Searchinger et al. calculations of carbon release
are based on trends recorded in the 1990s but are projected forward
up to 2016;
        * Improvements in biomass yields around the world are not
considered;
        * The U.S. spike leads to indirect effects around the
world without regard to regulatory limits (even in the U.S.).

    “These six shortcomings, together with the fact that the paper
is not replicable, since the models and parameters used are not
accessible, places a question mark over the refereeing procedures
used for this paper by the journal Science,” added John Mathews. “A
paper that seeks to place a procedure in the worst possible light,
and refrains from allowing others to check its results, is perhaps
better described as ideology than as science.”

    The full analysis – Biofuels and indirect land use change
effects: the debate continues – is available here.

    About John Mathews. Professor Mathews is professor of
strategic management at Macquarie University in Sydney, Australia.
As a specialist in technology and innovation, he is interested in
the renewable energy industries and in particular biofuels
industries. He has worked internationally with UNCTAD, UNIDO and
with the World Bank. He takes up the Foundation ENI Chair in
competitive dynamics and global strategy at LUISS Guido Carli
university, in Rome, in September.

    About Hao Tan. Dr. Tan holds a doctor of business
administration from Macquarie University in Sydney, Australia
(Vice-Chancellor’s Commendation For Excellence In Postgraduate
Research). He is currently supervisor research analyst and conducts
research on cyclical industrial dynamics which he has presented at
numerous international conferences.


Attachment www.arb.ca.gov/lists/lcfs09/421-analysis_of_biofuels_indirect_land_use_effects_finds_the_science_lacking.pdf
Original File NameAnalysis of Biofuels Indirect Land Use Effects Finds the Science Lacking.pdf
Date and Time Comment Was Submitted 2009-08-19 11:41:58

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