Comment Log Display

The Brazilian Sugarcane Industry Association (UNICA) welcomes the
opportunity to provide specific comments on “Detailed
California-Modified GREET Pathways for Brazilian Sugarcane Ethanol:
Average Brazilian Ethanol, with Mechanized Harvesting and
Electricity Co-product Credit (Version 2.2),” which the staff of
the California Air Resources Board (CARB) published on 20 July
2009. 

The attached letter expands on our previous correspondence 
regarding lifecycle calculations of sugarcane ethanol and includes
a number of specific recommendations concerning the calculations of
indirect land use change in the Low Carbon Fuel Standard (LCFS).
(See
http://www.arb.ca.gov/lispub/comm/bccomdisp.php?listname=lcfs09&comment_num=129&virt_num=107)

While UNICA is pleased that CARB has recognized several of our
recommended changes on the “direct” lifecycle calculations, we are
concerned about the delays in addressing the “indirect” land use
change component of the calculations for the LCFS. We strongly urge
CARB to act quickly in addressing the numerous concerns we –– as
well as a number of other stakeholders –– have raised with regards
to accuracy of CARB’s calculations of the indirect effects of
biofuels production. The alleged “indirect” land use change
penalty, currently set at 46 gCO2/MJ by CARB, is nearly four times
greater than the “direct” lifecycle of sugarcane ethanol as
calculated by the staff in the proposed new pathways. 

Following a brief introduction of UNICA as having a direct and
significant interest in these calculations, this letter focuses on
cogeneration credits, straw yield and trash content of cane
farming, cane transportation to the mill, energy consumption in
agricultural lime production, and maritime transportation of
ethanol. 

I hope this letter will contribute to improving the development of
the LCFS in California and remain at your disposal to answer any
questions you or your colleagues may have. 

Sincerely,
/
Joel W. Velasco
Chief Representative – North America
UNICA - Brazilian Sugarcane Industry Association
1711 N Street NW - First Floor
Washington, DC  20036-2801
Phone: +1 (202) 506-5299
Fax: +1 (202) 747-5836