Comment submitted by Macquarie Graduate School of Management (MGSM), Macquarie University (Australia)

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 calculat