Comment Log Display

April 17, 2009

Mary. D. Nichols, Chairwoman  
c/o Clerk of the Board 
Air Resources Board 
1001 I Street 
Sacramento, CA 95814 
 
Dear Ms. Nichols: 

On behalf of the South Dakota Corn Utilization Council, an
organization which seeks to protect markets for corn producers in
our state, I am writing today with grave concerns about
California’s proposed Low-Carbon Fuel Standard (LCFS). While I
respect the insurmountable task which has been laid at the feet of
the California Air and Resource Board to prepare regulations that
would allow California to reduce the state’s Greenhouse Gas (GHG)
emissions by 10 percent over the next decade, the rules recently
released by your organization have the potential to unravel current
strides made in reducing emissions and would likely accelerate land
use changes and GHG emissions – the reverse effect of what you
claim to achieve.

The fundamental flaw is the attempt to reduce GHG emissions on the
backs of the biofuels industry alone. The proposed LCFS within the
CARB rules attacks only transportation fuels for the burdens of
carbon that are discharged into the atmosphere, when in fact, all
economic activity generates GHG emissions.  A holistic approach to
GHG reduction must be employed; any other action would be
shortsighted and ineffective.

Burdening biofuels agriculture while exempting food agriculture
could have the effect of encouraging unsustainable land stewardship
in the developing world with the negative outcome of increasing net
GHG emissions around the world.  All economic activity should be
held responsible for the GHG emissions emanating from them if this
situation is to be avoided.

The precedence set by allowing flawed and exclusionary rules to
set standards for not only California but the nation, would be a
staggering detriment to our country and would slow the development
of technologies that can reduce our reliance on petroleum and other
fossil fuels. In the end, the reductions you seek will likely not
be reached because the reasoning is based upon a single-minded
approach. The proposed LCFS developed by CARB does not consider the
impact of other products and services that place significant carbon
burdens – many exceeding the footprint of renewable fuels.

There is opportunity before us and methods already being developed
which would provide the solutions you are seeking to bring your
state into environmental compliance. Science based decisions and
rule making which take into consideration ALL the impacts on GHG
emissions are imperative. Agricultural practices and technology are
already making positive impacts, promising to continually improve
our environmental footprint.

Proof of these advances were found by Field to Market, a broad
based alliance including food and agriculture interests tasked with
defining and measuring the sustainability of food and fiber
production. The group recently released the Environmental Resource
Indicators Report, which evaluated national-scale metrics over a 10
year period from 1987 to 2007 for land use, water use, energy use,
soil loss, and climate impact, and generated initial benchmarks for
corn, soybean, cotton and wheat production. 

The study evaluates both overall resource use, as well as resource
efficiency to demonstrate the positive change in each crop’s “field
print” over the past two decades. 
The Environmental Resource Report indicates several key trends are
beginning to emerge. Importantly, production agriculture has been
increasing efficiency over time, suggesting positive progress
toward meeting increasing demand for agricultural products while
achieving lesser environmental impact. 

Corn has seen modest to significant improvements in water use per
acre and in water use, energy use, and carbon emissions per bushel.
Consider the following facts:

•	Land use:  The amount of land needed to produce one bushel has
decreased 37 percent.
•	Irrigation:  Irrigation use per bushel has decreased 27
percent.
•	Energy:  The energy used to produce a bushel or unit of corn has
decreased by 37 percent.
•	Climate impact: Corn production has seen a 30 percent decrease
in emissions per bushel.

Agriculture is a select industry making tremendous advances of
this caliber on our nation. On behalf of the industry I urge your
board to reconsider the proposed rules and investigate more
effective actions for controlling GHG emissions.


Sincerely,



David Fremark, President
South Dakota Corn Utilization Council