The Environmental Working Group, Friends of the Earth, the Grocery Manufacturers Association, the National Marine Manufacturers Association, the National Petrochemical & Refiners Association, and the Natural Resources Defense Council have cosigned a series of letters to Senate leaders opposing additional study of the theory of indirect land use change. These groups would like to lock in the EPA’s current measurement of indirect land use change, which includes heavy penalties for corn- and soybean-based biofuels.
The coalition is responding to the inclusion in the American Clean Energy and Security Act of 2009 of Section 551, under the Agriculture and Forestry offsets. This part of the legislation directs the National Academies of Science to review existing studies of indirect land use change and determine whether models can reliably project the greenhouse gas emissions for both biofuels and conventional petroleum fuels.
According to Nathanael Greene of the NRDC, “This coalition has come together because we want sound science rather than special interests to determine our biofuels policies.” And according to the NPRA’s Greg Scott, “Sound, verifiable science should always guide the crafting and implementation of environmental and energy policy.”
So is the EPA’s current analysis of indirect land use change sound and verifiable? I’ve noted before that the EPA’s methodology is based on an assumption that there is a cause and effect relationship between production of renewable fuels and international land use change. Yet, they have not footnoted their assertion or demonstrated this cause and effect relationship. Sorry, but that’s not science, let alone sound and verifiable science.
Section 204(a)(3) of the 2007 Energy Independence and Security Act, the law that established the current RFS, already obligates the EPA to study whether there is an international impact from biofuel production. By December 2010, the EPA will have to come up with some direct evidence of the cause and effect relationship.
Section 203 of that same law asked the National Academies to study the issue of food and biofuel. Though the NAS appears not to have done the study, the Congressional Budget Office did complete a study. While showing that biofuels had roughly half the impact of oil on food prices, the CBO’s findings failed to explain roughly two thirds of food price increases during 2007 and 2008. The 2020 Project finds an easy explanation for food price increases in the profits made by members of the Grocery Manufacturers Association.
Politics is definitely about strange bedfellows. So, which of these groups will gain what from ensuring that biofuels are penalized for international land use change?