Comment Log Display

Jim Steitz
357 Vista Street Apt. 5
Ashland, OR 97520

April 21, 2009

Mary Nichols, Chair
California Air Resources Board
1001 "I" Street/P.O. Box 2815 
Sacramento, CA 95812 

Dear Chairwoman Nichols,

I write to urge the California Air Resources Board to include only
truly lower-carbon fuel sources in its pending Low Carbon Fuels
Standard, and to therefore specifically exclude agro-fuels made
from human food crops. There is a great danger that the new
low-carbon standard will actually increase California’s
contribution to global warming by promoting the use of agro-fuels
that actually cause more carbon dioxide pollution, not less.

The existing studies on the carbon metrics of agro-fuels are clear
and unambiguous. When America burns fuels made from agricultural
crops, it is a marginal or break-even proposition within America
and a dramatic increase in carbon emissions globally, as additional
demand bears upon agricultural commodity production. This demand
results in the destruction of rainforests and peatlands, releasing
vast stores of biological carbon that dwarf any possible savings
from displaced oil use. CARB must adopt a fuel standard that is
based upon empirical fact, not fiction formalized in a policy
document. If California allows agro-fuels into its new fuels
standard, it will dramatically increase California's contribution
to global warming. No plausible argument can be made against this
mathematical fact.

CARB’s decision on the agro-fuels issue is likely to set a
precedent for other states. A substantial national adoption of
agro-fuels will destroy whatever chance remains of substantially
mitigating global warming. America’s foray into ethanol has already
consumed approximately ¼ of America’s corn harvest, with nothing to
show except mega-soybean plantations in the Amazon where once
rainforest existed. In fact, the low-carbon fuels standard should
provide a specific penalty for fuels with an extra-high impact on
carbon emissions, above and beyond that of conventional oil,
including ethanol and gasoline derived from Canada’s “tar-sands”
oil. Only a true and accurate life-cycle assessment of carbon
impact can accurately guide the CARB standard, and such an impact
must exclude and specifically discourage agro-fuels and tar sands.

In addition to the impact of driving up global demand for
commodity crops, several studies, including Crutzen and Howard et
al. shows that nitrous oxide emission from heavy fertilizer
application contributes to global warming far more than previously
appreciated. Also, the fuel-intensive organization of the
agriculture industry ensures that every step of the process entails
significant energy consumption, resulting in a large amount of
“embedded emissions” in the final ethanol or other agro-fuels
product. The processes of harvesting, processing, transportation,
and refining are extremely fuel-intensive, and often involve
coal-fired electricity or direct emissions of extremely potent
greenhouse gases such as methane or nitrous oxide. In addition,
because the demand for land to grow most commodity crops is
fungible, American demand for corn is spread across the markets for
all other crops, including those at the frontier of ecological
destruction such as soybeans.

Again, please exclude high-carbon agro-fuels from the new
low-carbon standard, and provide specific penalties for especially
high-carbon fuels such as ethanol and gasoline from tar sands oil.
I submit that an intellectually honest and accurate assessment of
the various liquid fuel sources and feedstocks can lead to no other
conclusion. Thank you for your attention to this urgent issue.