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Comment 166 for Low Carbon Fuel Standard (lcfs09) - 45 Day.

First NameArlan
Last NameSuderman
Email Addressasuderman@farmprogress.com
Affiliation
SubjectLand Use Charge on Biofuels
Comment
I greatly respect the leadership that California is providing as it
seeks to be a good steward of the environment we live in. However,
I have significant concerns about the volume of old and misleading
data being used to shape public opinion on the land use charge for
biofuels. Based on the comments submitted, I see that many people's
opinions have been shaped by this old data that could lead to a
decision that is actually more detrimental in achieving your goals
of a healthy environment.

My success as a commodity analysts is not dependent on whether you
approve or disapprove the land use charge. My success though is
dependent on my thorough data analysis to sort through anecdotal
reports, assumptions and misleading information to get to the
truth. I simply analyze the facts as they're uncovered.

Ironically, I have found the land-use charge for biofuels issue to
be one of the most frustrating. The vast majority of public opinion
appears to be passionately shaped by old outdated studies that fail
to account for the significant shifts in technology achieved in
recent years, or it's simply based on long-held assumptions that
color one's interpretation of the facts. 

I won't take your time to review the facts, as I see from comments
already submitted that the biofuels industry has done an excellent
job of detailing changes in model results that accurately reflect
the facts that I've been able to uncover. I urge you to carefully
consider this data from highly respected models that have been
updated in the past couple of years to reflect current technology.
Only then can we be assured of a quality decision that truly
reaches our objective of a healthier and cleaner environment. 

I greatly appreciate your time and consideration,

Arlan Suderman
Market Analyst
Farm Futures

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Date and Time Comment Was Submitted 2009-04-21 15:33:02

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