Letter to the Editor on the article “Indirect land use change for biofuels: Testing predictions and improving analytical methodologies” by S. Kim and B. Dale

The article, “Indirect land use change for biofuels: Testing predictions and improving analytical methodologies” by S. Kim and B. Dale, presents a principal inference not supported by its results, rests on a fundamental conceptual error, and has no place in the current discussion of biofuels’ climate effects. As it is already receiving press attention as though its findings are considerable, it requires a detailed refutation. Briefly, the most important errors in the paper are • taking correlation between two variables in a system with many interacting factors to indicate (or contraindicate) causation, • drawing a completely incorrect inference from observed sample statistics and their significance levels, and • misunderstanding “the question” about ILUC, which is not whether biofuels production causes total deforestation to increase, but whether it causes it to increase more, or reforestation to increase less, than would happen without the biofuel program.JRC.F.7-Renewable Energ