In comments submitted today, the Renewable Fuels Association is urging the U.S. Environmental Protection Agency to exclude several candidates from consideration to serve on a peer review of the agency’s upcoming triennial report to Congress on the environmental impacts of the Renewable Fuel Standard (RFS). RFA argues that several of the final candidates for the peer review committee have demonstrated an obvious ideological bias against commercial agriculture and renewable fuels like ethanol.
Under the 2007 Energy Independence and Security Act, EPA is required to submit regular reports to Congress on the environmental and resource conservation impacts of the RFS, and as part of the process it recruits external candidates to peer-review the report before it is published. For its third report, following two earlier studies submitted in 2011 and 2018, EPA has proposed a list of 20 candidates from which the agency will select up to nine peer reviewers.
“Some of these candidates have long-standing histories of ideologically biased statements and positions, dubious scientific work, and conflicts in sources of funding that may lead to sponsorship bias,” the association stated. Additionally, “RFA finds the proposed list to include a disproportionate number of candidates representing certain issue areas, and RFA has concerns about the group’s ability to complete a thorough review without complete and balanced representation.”
RFA urged EPA to exclude Tyler J. Lark of the University of Wisconsin-Madison, whose work was cited extensively in the EPA’s Second Triennial Report to Congress, from further consideration. With the likelihood that Lark’s recent research may be discussed in the Third Triennial Report, it would be inappropriate for Lark to serve as a peer reviewer for this report. RFA also noted that Lark’s previous work related to biofuels has suffered from known flaws and inaccuracies, which have been willfully repeated by him in subsequent works.
Another candidate RFA is urging to be excluded is Jason D. Hill of the University of Minnesota, who has shown “a similar history of bias, unwillingness to respond to legitimate critiques of his work, and unsupported and provocative statements about the RFS and corn ethanol.” A third candidate, Timothy D. Searchinger of Princeton University, has had his work on indirect land-use change thoroughly refuted and rejected by the scientific community. RFA encouraged EPA to remove Searchinger from further consideration, as he “cannot be considered impartial or fair-minded.”
RFA concluded by urging transparency in the triennial review process. “Given that the list of peer review panel candidates is generally lacking experts with knowledge in contemporary agricultural feedstock and biofuel production methods, we strongly encourage EPA to ensure that representatives of the existing biofuels industry are allowed to provide their perspective and feedback on both the triennial report and the peer-review process. We believe biofuel producer groups, farmers, and other members of the public should be allowed to observe the peer-review process as it occurs, including any virtual or in-person meetings or conferences, as well as access to written correspondence between the peer reviewers and EPA (and its contractor, ERG).”
In the past, RFA has found significant issues in the prior two EPA triennial reports to Congress, involving some of the same candidates on the list EPA has proposed for this new review of the RFS. Click here for an RFA analysis of the preliminary 2011 report, and here for a look at two studies that significantly question some of the key results of the 2018 review.