Comment Log Display

March 25, 2009

Mary Nichols, Chairman
California Air Resources Board
1001 I St., P.O. Box 2815
Sacramento, CA  95812

Re: California Low Carbon Fuel Standard

Dear Chairman Nichols and Members of the Board:

The Union of Concerned Scientists (UCS) applauds the California
Air Resources Board (CARB) for developing the framework for a
performance-based standard to reduce global warming pollution from
our transportation fuels. By holding fuel providers accountable for
emissions from the entire life cycle of making and using a fuel,
the Low Carbon Fuel Standard will not only protect California from
dangerously high-carbon fuels, like liquid coal and petroleum from
tar sands, but also has the potential to provide incentives for a
new generation of cleaner transportation fuels. 

UCS also strongly supports CARB’s inclusion of indirect land use
changes from biofuel production. The science is clear on the
basics: increased demand for crops to make fuel results in higher
global commodity prices that can induce farmers in other countries
to plow up sensitive ecosystems - including rain forests in South
America and Southeast Asia that have a high degree of biodiversity.
For some carbon-rich land types such as forests, a great deal of
global warming pollution can be released from the soil and trees
when this land is cleared and plowed. 

The scientific debate will continue on which methods and models
can best calculate the emissions from such indirect land uses
changes, but CARB’s proposed values are, if anything, conservative.
Any fuels policy that ignores the indirect consequences of biofuels
production can lead to perverse outcomes that appear to decrease
emissions in the U.S. fuel sector, but actually increase global
warming pollution worldwide.

UCS sees several opportunities to strengthen the LCFS, including:

* using a science-based accounting for greenhouse gas emissions
over time to account for the global warming potential of
heat-trapping gases accumulating in the atmosphere;

* ensuring the LCFS provides real pollution reductions and ushers
in a new generation of ultra low-carbon fuels;
including minimum safeguards to ensure the LCFS does not provide
unintended incentives for fuel production that result in ecological
harm to our federal lands, forests, and other sensitive
ecosystems;

*including metrics to ensure the LCFS provides incentives for the
development of broadly sustainable alternative fuels, while
avoiding unintended support for fuels with negative environmental
or social impacts, such as raising food prices; and

* setting protections for California's air quality and public
health.

While there is room for the LCFS to be strengthened, UCS commends
CARB for setting the framework for a cutting-edge fuel policy
founded on a basic principle: the LCFS sets a performance standard
and allows fuels compete in the marketplace to meet the standard,
without picking winners or losers. There is still time to avoid the
worst consequences of global warming, but it is critical that
California gets the full emission reductions possible from our
transportation fuels.

Thank you for the opportunity to comment on the staff proposal for
the LCFS. UCS will submit more detailed and complete comments
before the end of the public comment period. 


Sincerely, 

Patricia Monahan
Deputy Director for Clean Vehicles

Chris Carney
Western Region Outreach Coordinator


The Union of Concerned Scientists is the leading science-based
nonprofit working for a healthy environment and a safer world. UCS
combines independent scientific research and citizen action to
develop innovative, practical solutions and to secure responsible
changes in government policy, corporate practices, and consumer
choices. Founded in 1969, UCS is headquartered in Cambridge,
Massachusetts, and also has offices in Berkeley, Chicago, and
Washington, D.C. For more information, go to www.ucsusa.org.