Global Renewable Fuels Alliance

GRFA Letter to HLPE Steering Committee re. Withdrawing Biofuels and Food Security Report

Dear Chairman Swaminathan,

We are writing to express the global ethanol industry’s grave concerns about the lack of transparency, openness, and scientific integrity surrounding the HLPE’s Biofuels and Food Security project that culminated with the publication of an imbalanced report and impractical policy recommendations in June 2013. Specifically, we are dismayed by the manner in which the project scope was finalized, the mysterious process for appointing the Project Team, the apparent disregard for stakeholder feedback provided during consultations, the opaque and secretive “external review” of the final draft report and the lack transparency on the donors who funded the exercise as well as the level of funding. Given that the report is intended to inform critical public policy decisions, we believe the HLPE should withdraw the report until basic procedural deficiencies are addressed and the public has an opportunity to participate in an open and transparent deliberative process.

In May 2012, the HLPE quietly launched a 20-day “e-consultation” intended to “…seek views, public feedback and comments, on the pertinence and relative importance of some key questions that the report proposes to address…” The HLPE states that the purpose of its consultations is to “…open the process to the input of all experts interested…as well as to all concerned stakeholders…” and that feedback is “…considered by the Project Team and enriches the knowledge base.” Despite the relatively discreet nature of the consultation on the proposed study scope, the HLPE received substantive feedback from a diverse cross-section of stakeholders. Many of the stakeholders responding encouraged the HLPE to narrow the proposed scope of the project to better comport with the directive from the CFS to focus narrowly on food security. Stakeholder comments also encouraged the HLPE to properly contextualize the potential impacts of biofuels on food security by comparing them to the food security impacts associated with other forms of energy, namely fossil fuels. However, these recommendations and others were dismissed without explanation by the HLPE as it set the project track. It is a basic principle of any open and transparent public process that decisions to accept or reject recommendations from stakeholders be explained and appropriately justified. Unfortunately, the HLPE’s rationale for rejecting public suggestions regarding the study scope remains unclear. We believe the HLPE owes an explanation to stakeholders who submitted legitimate recommendations on the study scope that were ultimately rejected.

The puzzling process by which the Project Team was selected is equally concerning. In the interest of openness and transparency, the general public should have been allowed to participate in the process to assemble the Project Team. Stakeholders should play a key role in nominating and vetting potential Project Team members. Inappropriately, the HLPE established the Project Team for this task without seeking any recommendations or nominations from the public. In other words, the Project Team was “hand-picked” by the HLPE without any consultation of the public or affected industries. While some members of the Project Team have exhibited a balanced, fair, and science-based approach to examining the socio-economic impacts of biofuels, others have demonstrated ideological bias against commercial agriculture and biofuel production. One Project Team member is a known detractor of large-scale agriculture and was the primary author of a highly controversial, outdated, and broadly rejected analysis of the hypothetical land use impacts of expanded biofuels production. Not surprisingly, this 2008 analysis is cited at multiple points in the final HLPE report, without any reference whatsoever to the numerous responses and rebuttals it drew from other scientists. It is our belief that a more balanced Project Team would have led to a more balanced final report. Greater balance likely could have been achieved had the HLPE engaged the public in the process to nominate, evaluate, and select Project Team members.

In early 2013, the HLPE conducted a second consultation following the release of its “Version 0” draft of the report. This consultation received more than 60 formal responses, most of which offered substantive recommendations for eliminating subjectivity, improving the balance of views expressed, enhancing scientific rigor, and tightening the focus. Like the feedback submitted during the first consultation, the Project Team and HLPE generally rejected input provided by stakeholders during the second consultation without explanation.

Finally, we take issue with the manner in which the external review of the final draft report was conducted. The HLPE states that draft reports are to be “…submitted to independent evidence-based review.” However, it is unclear whether the HLPE process meets the basic standards of external peer review. It is customary for peer reviewers to be acknowledged by name in the final report. It is also normal, and desirable, to select peer reviewers whose viewpoints differ from the authors’ perspectives. Subjecting the work to a rigorous critique by experts with disparate views helps ensure it will stand up to public scrutiny. Because we have no information on the HLPE external review process, it is unknown whether any of these basic peer review principles have been satisfied. As such, we request that the HLPE provide information on its external review process and disclose the names and affiliations of the peer reviewers.

In conclusion, sound science and an open, transparent, deliberative process that involves the public, best inform effective policy. It is unfortunate that the Biofuels and Food Security project has, so far, largely excluded or disregarded the views of industry stakeholders and the general public. The HLPE overlooked suggestions from the public regarding the study scope, failed to engage the public in the process to assign the Project Team, disregarded stakeholder comments on the V0 draft, chose not to identify who funded the exercise as well as the level of funding and neglected to conduct a truly transparent external review of the final draft. Because of these serious procedural shortcomings, we encourage the HLPE to withdraw the report until these deficiencies are appropriately addressed and the public has been given a real opportunity to participate.

Thank you for your consideration of this request. Please do not hesitate to contact us at info@globalrfa.org or visit www.globalrfa.org. We look forward to working with the HLPE and would welcome an opportunity for provide input into this process so to restore openness and transparency to the project.

Sincerely,


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