Comment Log Display

April 20, 2009


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

RE:   The California Low Carbon Fuel Standard

Dear Chairman Nichols:

The California Low Carbon Fuel Standard (LCFS) should be an
important step in the fight against global warming, particularly as
it aims to reduce the carbon intensity of the state’s
transportation fuels by at least 10 percent by 2020.  We fully
endorse the principle of such a standard, however, we believe that
changes to the draft legislation are needed to ensure that it will
actually mitigate climate change.  Specifically, the inclusion of
agrofuels (industrial biofuels) threatens to undermine the impact
of the legislation and could lead to it actually exacerbating
global warming.  Rules being developed by the California Air
Resources Board (CARB) will dictate the future of California’s
transportation sector for the next two decades. The California LCFS
is also likely to set a national precedent, as other states look to
California as a model for how to achieve similar carbon reductions.


Provided that agrofuels are excluded, the LCFS could substantially
reduce California’s carbon emissions by penalizing oil companies
for refining raw materials that have a higher a carbon footprint
than that of conventional oil. The dirtiest of these raw materials
include synthetic crude oil made from sticky bitumen mined from
Canada’s tar sands.  

We encourage CARB to adopt a precautionary approach and to exclude
agrofuels from the LCFS given current evidence of serious negative
impacts on forests, climate and food security.  
To ensure we obtain real reductions in carbon and achieve the full
economic benefits of the LCFS without sacrificing California’s and
other domestic and international public lands, forests and
sensitive ecosystems, it is critical to avoid pitfalls that would
compromise the success of the regulation.  

When considering the inclusion of agrofuels, it is important to
recognize that emissions from indirect land use change (iLUC) are a
major source of pollution, loss of biodiversity and escalating food
prices. There is no one standard methodology that has been accepted
as a legitimate way of measuring all indirect impacts associated
with agrofuels production whether they relate to climate,
biodiversity or food security, among other issues.  Yet, the risks
of serious unintended consequences are real and well documented and
cannot be fully addressed by the currently available methodologies
that CARB has embraced.  
•	All standard methodologies for calculation of carbon intensity
of biofuels both ignore indirect emissions and actually presume
major ‘indirect greenhouse gas savings’ from the use of biofuel
co-products.  This is not a full accounting of the lifecycle of
agrofuel production.
•	Evidence provided by Paul Crutzen, Howarth et al., and
Searchinger et al. among others, that indirect nitrous oxide
emissions from agrofuels linked to the use of nitrogen fertilizer,
or from legume monocultures, are far higher than suggested by IPCC
methodology has not been fully assessed, nor has it been addressed
in any way by the IPCC.     This alone means that there is no
scientifically credible way of calculating life-cycle greenhouse
gas emissions from agrofuels.
 

Proponents of agrofuels claim that cellulosic and other “second
generation” fuels will have a reduced carbon footprint.  While
these fuels are not yet commercialized, current evidence suggests
they may have a worse environmental impact than fossil fuels.    We
know from peer-reviewed studies that every industrial agrofuel
feedstock is more greenhouse gas emitting than petroleum.  The lead
author of one such peer-reviewed article, Joseph Fargione, has
clearly stated “From a climate change perspective, current biofuels
are worse than fossil fuels.”  
When all impacts are assessed, agrofuel production not only does
not deliver reductions in greenhouse gases but actually increases
global warming emissions, particularly when forests, peatlands and
wetlands are converted as a direct or indirect impact of biofuels.
The International Energy Agency estimates that over the next 23
years, the world could produce as much as 147 million tons of
agrofuels. This will be accompanied by massive amounts of carbon
and nitrous oxide emissions, erosion, and over 2 billion tons of
waste water. Remarkably, this fuel will barely offset the yearly
increase in global oil demand, now standing at 136 million tons a
year—without offsetting any of the existing demand.

We cannot substitute one liquid fuel (petroleum) with another
(agrofuel) which is just as destructive:

•	To avoid the worst consequences of global warming, CARB must not
only make our cars and trucks more fuel-efficient and less
polluting, but work to provide real transportation alternatives
such as expanding mass transit; creating bike and
pedestrian-friendly cities.
•	Also, CARB should work to encourage less overall consumption of
energy, including transport fuels so that we do not continue to
pursue inefficient and unsustainable alternatives, such as
agrofuels, to meet our insatiable demand.

Thank you for your consideration of these comments and
suggestions,

Rainforest Action Network
Food First—Institute for Food and Development Policy
Food and Water Watch
Organic Consumers Association
Global Justice Ecology Project
Dogwood Alliance
Biofuelwatch UK