Comment Log Display

It is clear from the record that CARB staff has been selective in
its use of available data to determine corn ethanol coproduct
credit values.  CARB staff should redo this evaluation, relying
upon the most recent data available and local animal nutrition
scientists at the University of California, and the California
State Universities, and the CA Department of Food and Agriculture.

It is also clear from the record that there is tremendous
uncertainty, not only in the magnitude, but also in the direction
of market mediated, or indirect land use change effects.  No
alternate scenario analysis using GTAP (or any other eceonomic
model) has been run by CARB staff and their supporting consultants
at UC or Purdue using alternate land use assumptions such as those
presented by Kline, et al at Oak Ridge National Laboratory.  Nor
has this theory been validated using real world on-the-ground data.
 An equally plausible assumption is that available underutilized
agricultural land will be used to meet expanding food, feed, fiber
and energy demand, rather than the assumption that ANY new demand
(biofuel or otherwise) will be met by converting forest or
perennial grasslands into new agricultural land.  I respectfully
request that this issue be analyzed during the next two years under
the direction of the National Academies of Science.

Finally, CARB staff should be commended for its use and on-going
refinement of the GREET model to quantify direct impacts. A LCFS
regulation based on direct impacts as quantified by the CA GREET
model should be implemented starting in 2010.  

It is a shame that the coproducts credit analysis and the ILUC
portion of the regulation have not been affored the same rigor. 
The fact that they haven't reflects poorly on the credibility of
the entire regulation.

Respectfully,
Steve Shaffer