Comment Log Display

April 22, 2009

Mary Nichols, Chair
California Air Resources Board (CARB)
1001 I Street
Sacramento, CA 95812

Subject: Strong Support for LCFS, But Proposed Biofuel Emissions
Are Overly Conservative

Dear Chairman Nichols and members of the Board,

We appreciate the opportunity to comment on the proposed Low
Carbon Fuel Standard (LCFS) regulation.  UCS strongly supports
California’s pioneering effort to regulate lifecycle pollution from
transportation fuels. The standard, which is a model for the
country and other nations, will provide a mechanism for moving away
from today’s petroleum-based fuels towards tomorrow’s cleaner,
renewable, and more sustainable fuels. The LCFS provides an
elegant, market-based structure to de-carbonize our fueling
system.

We recommend strengthening certain aspects of the regulation, as
articulated in the comment letter we submitted jointly with 35
other groups on April 15.  The rule should be strengthened to
prevent air quality backsliding, ensure ultra-low carbon fuels are
used in California, protect sensitive lands, and promote
sustainable fuels production.  

We commend you and your staff for your groundbreaking work in the
important area of lifecycle analysis, and particularly for
grappling with the urgent and complex task of quantifying emissions
associated with indirect land use changes (iLUC) induced by
increased production of biofuels feedstocks.  However, we find that
staff’s proposed carbon intensity values for biofuels may be too
low for the following three reasons. First, the staff’s proposed
methodology to account for CO2-equivalent emissions (CO2e) over
time undervalues the impact of biofuels that cause land use change.
Second, the staff has adjusted the GTAP model variables to increase
yields of biofuel feedstocks without increasing direct emissions
from fertilizers and other inputs.  Third, there is growing
evidence that the direct emissions from fertilizer use may be
higher than estimated in the LCFS. 

We urge the Board to send a clear signal to conventional biofuel
producers that the current carbon intensity values for biofuels
will likely be adjusted upward in the next review of the program.
The following provides more detail on why the carbon intensity
values for biofuels may be too low. 

(consult attached document for remaining comments)