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Dear Clerk of the Board:

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April 21, 2009

Mary D. Nichols, Chairwoman
California Air Resources Board
c/o Clerk of the Board
1001 I Street
Sacramento, California 95814
Electronic submittal:
http://www.arb.ca.gov/lispub/comm/bclist.php


Dear Chairwoman Mary Nichols:

Many congratulations on your and other board members’ tireless
efforts in establishing what will become an LCFS framework for many
states, and perhaps the nation.  In particular, it is intriguing
that ARB has been able to select a couple of scientific studies for
the indirect land use change (iLUC) of biofuels, particularly when
the majority of uninvolved knowledgeable scientists agree that this
topic is very early in its development, the science cannot be
backtested, and that is has to be based on assumptions.  By
choosing those that have the most damaging outcome for biofuels,
you have certainly made many of those vocal in the environmental
arena very pleased.  It is especially interesting that you have
been able to select indirect effects for certain biofuels alone,
and have left off those for other fuels.  Of particular interest is
that while at least half of California’s petroleum comes from other
regions such as the Middle East and Colombia, and in the future
will increasingly rely on carbon intense (and other extreme
environmental damages) tar sands and oil shale, you have been able
to establish the LCFS for gasoline as merely that domestic to
California.

The LCFS iLUC values for biofuels results directly from assumptive
computer modeling done by Timothy Searchinger of Environmental
Defense, and Joseph Fargione of the Nature Conservancy. 
Environmental Defense receives funding from W.K. Kellogg Foundation
(the Kellogg’s that is part of the Grocery Manufacturers
Association which funded an aggressive anti-corn ethanol PR
campaign starting in early 2008).  Kellogg also provides funding to
the Nature Conservancy and to the Rockefeller Family Fund (obvious
connections to ExxonMobile).  The Rockefeller Family Fund provides
funding to the Environmental Working Group, which has been
consistently negative to corn ethanol and large corn farms in
general.  Another source of funding is the Joyce Foundation, which
provides funding to the Union of Concerned Scientists (who have
submitted their comments and 177 scientists letter to ARB in favor
of biofuels’ iLUC outcome), the Nature Conservancy, and the
Environmental Working Group.

Joseph Fargione (Nature Conservancy) is tied into Searchinger’s
work through Environmental Defense, both funded by W.K. Kellogg. 
The Washington Post on May 4, 2003 published an investigative
report on the Conservancy.  Though it had its purposeful upstart
decades early, the Conservancy had greatly expanded to the point
that it had officials with large polluting corporations on its
board, who would use it for positive PR about their environmental
projects.  It was revealed that ExxonMobile and BP hold leadership
counsel seats on the Conservancy, donating $5 million.  Philips
Alaska, a supporter of drilling in ANWR, donated $1 million. 
Regarding land use change, the Conservancy forged a partnership
with Centex Homes, which up to 2003 had built 400,000 homes in
urban sprawl (Centex had given and pledged $3 million to the
conservancy).  Also allied with the Conservancy are International
Paper and Georgia-Pacific ($3 million given), logging companies. 
The logo of the Conservancy was used on General Mills’ products,
which held a seat on the board of the Conservancy and is a member
of the Grocery Manufacturers Association.

The information is available at:

 
http://pqasb.pqarchiver.com/washingtonpost/access/332205031.html?dids=332205031:332205031&FMT=ABS&FMTS=ABS:FT&fmac=&date=May+4%2C+2003&author=&desc=TODAY+++Inside+the+Nature+Con+...
 
http://www.wildlifeprotection.net/everything/NatureConservency.html
 
http://www.discoverthenetworks.org/groupProfile.asp?grpid=6940

Sitting on today’s board of the Conservancy is Stephen Polasky,
who in early 2009 followed up with a study determining that corn
ethanol also would release as much or more CO2 emissions as
gasoline.

http://www.greenbiz.com/news/2009/02/06/corn-ethanol

http://www.nature.org/aboutus/leadership/art15462.html

Regardless of their stance on corn ethanol, the absurdity of GM
having their Senior Advisor and former Corporate Vice President on
the Conservancy Board seems to further decrease its integrity,
pointing out that still today it is not the
environmentally-focused, corporation-disconnected group from its
early days.

Also serving on the Conservancy board is former under secretary of
state for global affairs and climate change, Frank Loy.  He also
serves on the board of Environmental Defense.  A third board he
sits on is the Pew Center for Global Climate Change, which is
funded by Sun Oil/Sunoco, and now also includes BP and Shell. 
Together, the Pew Center and Environmental Defense formed the
Partnership for Climate Action (PCA).  A strong endorser of
market-based mechanisms to reduce carbon dioxide emissions, the
individuals and companies of PCA plan to benefit handsomely from
the profits.  There are some other big partners in PCA now—Carlyle
Group, Berkshire Partners, Morgan Stanley, the CEO of Carbon
Investments, and Goldman Sachs.  The latter invested in
photovoltaics with Sun Edison, acquired Horizon Wind Energy, and
purchased a stake in Iogen Corp., a cellulosic ethanol company that
would likely benefit from a higher corn ethanol iLUC and LCFS
value, and Goldman Sachs has touted itself to become “the market
maker in CO2 emissions trading.”  On the Conservancy board sits
Maneer Satter, Managing Director at Goldman Sachs.

This information is found here:

http://www.globalresearch.ca/index.php?context=va&aid=5568

This ties investment banks, food companies, and oil companies to
the researchers that ARB is  basing its iLUC and LCFS values for
corn ethanol and other biofuels upon.  Daniel Sperling, ARB voting
member, published his “Low Carbon Fuels Standards” in the Winter
2009 issue of Science and Technology.  ARB has also linked his
papers on their website.  His article, which is highly critical of
corn ethanol, references Timothy Searchinger as one of three
sources of information.  Indeed, Daniel Sperling has a long
relationship with the oil and automobile companies, and his
Institute of Transportation Studies at UC Davis receives million of
dollars from these same companies, also including Chevron and
ExxonMobile.

This information is found here:

http://articles.latimes.com/2008/apr/11/business/fi-airboard11

There are numerous other seeming conflicts of interest that exist
with voting members, going straight to the top, at ARB and CEC that
I will not detail, as they involve marriage relationships (spouses
employed by large oil companies and lobby firms) and very
significant personal financial stakes in oil companies.  These have
been reported in the mainstream press should anyone be interested.

The issue at hand is that corn ethanol and soybean biodiesel are
not easily controlled financially by these large fuel companies. 
Hydrogen, electricity, natural gas, etc. seemingly would be.  Also,
the investment banks and food companies have a vested interest in
decreasing the use of corn ethanol and controlling the carbon
trading market.

You see how this presents a problem, when the only indirect
effects that ARB is considering at this point are those of these
biofuels.  I strongly encourage you to include direct effects, but
only when all can be scientifically (not assumptions and worst case
computer models that can’t be backtested) agreed upon by the
majority of uninvolved scientists.  ARB is not at that point, and
would be allowing itself to be an instrument of the above conflicts
were it to continue with the absurdity of the current iLUC and LCFS
values of these biofuels alone.

Respectfully,

Bob Winnson