Comment Log Display

I am a latecomer to these deliberations, a participant in the
Roundtable on Sustainable Biofuels. I have no knowledge of the
models CARB may be using for LCFS indirect land use change
assessments on biofuels but I have some considerations to suggest.


The biofuels industry is greatly sensitized to the use of
food-producing lands for biofuels. It can be expected that many
land use changes associated with biofuels will involve the use of
existing agricultural lands that are either idled or damaged.
Additionally, biofuel crops can be grown on marginal lands, which
may involve land use changes. 

Are there carbon sequestration credits for use of damaged or
marginal lands included? These uses are likely to enhance the
lands’ carbon capacity. 

Are there carbon costs allocated to biofuel crops as a result of
crop rotations? How are you distinguishing between a rotation and a
new land use? 

Further, if new ag lands aren’t burned or plowed, there will be
little carbon loss, and if the land is cultivated well, carbon
capacity will increase appreciably, quickly and over time. Is this
information included? It seems to me to be another possibly
significant set of carbon credits. 

How are your sorting out these kinds of land use changes? The
largest concern here seems to be deforestation. To my knowledge,
none has occurred yet solely for biofuel production,
internationally. 

Finally, land use change carbon impacts depend on site-specific
factors – current use, soil organic content, how the land was
prepared and subsequently managed. Are these factors incorporated
in your models? 

No one I am aware of has been able to account for these factors
completely. While I agree with the goal of including indirect land
use changes in LCFS, we don’t have the data or the current
collection capacity required for an appropriate or accurate
assessment. 

Future study of indirect land use impacts associated with
biofuels, and all other energy resources, is prudent. Today,
however, I believe the best we can do is an assessment of their
direct production and use effects. 

The Board should acknowledge possible indirect land use change
effects associated with biofuels in setting a LCFS and urge further
study. Indirect land use effects as currently developed should not
be included.  

Throughout the history of the petroleum industry, vast urban and
economic development, there has never been consideration of carbon
emission effects. Why have renewable low carbon fuels suddenly made
land use change this important?