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Validity of RFS report questioned

Biofuels have the potential for environmental and national security benefits compared to petroleum use. But the outcome depends on many factors, including feedstock, management practices, possible land-use changes and water availability.

As soon as a report assessing the economic and environmental impacts of the federal Renewable Fuels Standard (RFS) was issued by the National Research Council (NRC), many questions about the validity of the report's assumptions and the currency of its data began circulating. Everyone from Agriculture Secretary Tom Vilsack to biofuel industry leaders to advocacy groups cast doubts on the congressionally-mandated study. Vilsack said the report bases its conclusions "on information that's not as accurate as it once was." Even the NRC study co-chairs acknowledge in the preface that, "our clearest conclusion is that there is very high uncertainty in the impacts we were trying to estimate. "

Another figure who brings significant credentials to this debate is Dr. Virginia Dale, the director of the Center for BioEnergy Sustainability at DOE's Oak Ridge National Laboratory and one of 16 experts on the NRC committee that crafted the report. Dale acknowledges that, like most NRC reports, the RFS study represented a compromise among the largely academic committee members, including her. But she also says there is a paucity of data on the subject, requiring the committee members to largely base their report on model projections.

Dale goes on to point out that with any scientific process, it is difficult to reach a conclusion when (a) the data are inadequate, (b) some models are applied at scales inappropriate to the situation, or (c) key processes are not included in the theories. All of these limitations, she says, are applicable to current analyses of the effects of biofuels.

Biofuels have the potential for environmental and national security benefits compared to petroleum use. But Dale acknowledges that the outcome depends on many factors, including feedstock, management practices, possible land-use changes and water availability - all variables that are site-specific and continually change with technological advancements and innovation within the industry.

And because of that variability, she said parts of the report can be misleading "if the assumptions of the analysis are not considered appropriately. Strictly speaking, this report is not a conclusion and should not be read as such but rather a report on work in progress," she adds.

She cautions policy makers - all readers, in fact - to read the report details with care, noting that the assumptions, scales and caveats of analyses and results are critical to the interpretation and any extrapolation of the results.

Dale says model projections are not to be "believed" so much as treated as potential futures implied from a set of specified scenarios and assumptions. The environmental researcher says that while models can enhance understanding, they must be validated by empirical information. And so far, she asserts, the empirical evidence provides little, if any, support for modeled projections of land-use change.

Inherent risks

Dale concurs with Secretary Vilsack's assessment that "the report is not based on the most current information." She cites as an example the failure of the report to consider the U.S. Billion Ton Update study, which details biomass feedstock potential nationwide, pointing out that, instead, outdated estimates of biomass production were used. Furthermore, she notes, the report does not include current information from bioenergy technology industries due to lack of published results and restrictions of proprietary data. Vilsack struck on a similar theme Tuesday when he said the report does not acknowledge the efforts being made in support of technological advances that can accelerate the development of the next generation of biofuels, including a series of recently announced USDA loan guarantees for advanced biofuel refineries under development in Hugoton, Kansas, and Emmetsburg, Iowa.

The 25x'25 Alliance concurs with Dr. Dale's assertion that biofuels represent a complicated issue, but that today's biofuel ventures must be willing to take the risks inherent in a new industry, despite many uncertainties and constraints. The eventual success of private enterprises for feedstock production, transport, conversion, delivery and use of biofuels, she says, depends on "contextual socioeconomic and environmental conditions."

While some critics would ignore the advances the biofuels industry is making and use the NRC report to attack the RFS, the Alliance believes it's critical to remember Dale's conclusion about the report: "The answer to the question of what are the economic and environmental effects of biofuels is that 'it always depends' on a broad set of preexisting conditions, trends and available options, with no one solution being the best for all situations."

Policy makers should continued their commitment to the federal Renewable Fuels Standard because it creates the market stability critical to creating and maintaining American jobs, helping insure U.S. energy security and improving the environment.

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