Comment Log Display

On Thursday, please vote against the California Air Resources Board
proposed rule limiting the carbon content of transportation fuels. 
The proposed rule is overreaching and will have the unintended
consequence of propping up the status quo of our country’s
continued reliance on fossil fuels.  

Among other adverse effects, the proposed rule would discourage
investment in the biofuels industry and would therefore limit the
growth of biofuels as a viable alternative to oil.  Moreover, this
would happen at the precise time when the critically needed
transition to the next generation of cleaner fuels is gaining
momentum. 

In particular, including the indirect effect of land use in
determing the carbon content of a fuel is especially problematic. 
Not only is the scientific community not in agreement on how to
measure and value such a figure, to apply the land use analysis to
biofuels alone is intellectually inconsistent and unfair, if not
unconstitutional.  

Obviously all energy production – from fossil fuels to green power
sources like solar and wind – has land use consequences.  But
without an established scientific consensus as to how to quantify
the effects of land use for energy production, this step should not
be taken.

Everyone recognizes the need for cleaner air.  But punishing and
discouraging biofuels is not the path to a greener future, but
rather, a vote for the status quo addiction to domestic and
imported fossil fuels.

 
Best Regards,

Mark Cole
General Counsel
US Development Group LLC