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My company has been involved with alternative fuels since it was
founded here in CA in 1987.  It has always been axiomatic that such
fuels much have an energy efficiency for the entire process from
obtaining the raw materials to use  with matching energy content
(or reduction in carbon emission to make up the difference) to
fossil fuels.  If not then the carbon emission are actually larger
for the same energy output because you need more fuel.  

In cases like corn ethanol there is only an advantage if there is
a cap on gasoline being used so that the extra carbon dioxide from
ethanol forces a commensurate reduction.  When you use a sugar to
make ethanol it ALL ends up as carbon dioxide and the energy
content of the fuel part is less than gasoline.  Ethanol makes
sense when it is made from wastes which will make the equivalent
amount of carbon dioxide if nt turned into fuel.

Currently CA condones the wasteful process of green waste
composting.  This generates huge amounts of carbon dioxide and when
done incorrectly also produces significant amounts of methane.  My
calculation indicates that this is a significant source of
emissions in CA.  Importing starch, sugar or fuels made from starch
crops and sugar is also much less efficient when making fuels with
less energy content, for example, making butanol is energetically
better than making ethanol.

It is my hope that CARB will recognize that many of the
alternative fuel programs such as corn ethanol, plasma
gasification, air blown gasification, pyrolysis, etc. are not as
effective as other waste to fuel, waste to energy processes or even
crops grown for the purpose near the source of manufacture of the
fuel or energy.

The well (raw materials) to wheels analysis should make any
alternative at least as good as the electric vehicle or "natural
gas" vehicle based on anaerobic digestion or non-air blown
gasifications of wastes.

Let us not make the mistake of the 1980s wherein uneconomical and
energy deficient processes were commercialized and failed by the
scores with wind energy being the only real survivor here in CA. 
CARB can lead the way by implementing strict energy and emissions
criteria that will prove benefits and not just create "ventures"
that will fail in keeping the air clean as well as economically.

We need to stop composting ad turn that material into fuels.

Wiliam A. Farone, Ph.D.