Comment Log Display

The Brazilian Sugarcane Industry Association (UNICA) submits the
attached comment letter on the U.S. Environmental Protection
Agency's proposed rulemaking for the Renewable Fuel Standard
program (the “RFS2 Proposed Rule”). See Notice of Proposed
Rulemaking, Regulation of Fuels and Fuel Additives: Changes to
Renewable Fuel Standard Program, 74 Fed. Reg. 24903 (May 26, 2009).


We believe the topics covered in UNICA's comments on the RFS2,
which include recommendations related to direct lifecycle
assessment and indirect land use change calculations, are directly
relevant to the implementation of the LCFS.

Based on the conservative results of a Brazil-specific,
partial-equilibrium land use model for the “indirect” emissions and
the required emission credits from bioelectricity, the revised
results for the sugarcane ethanol pathway should be revised to 82%
and 73% for 100 year with a 2% discount rate and 30 years with no
discount rate, respectively.

As a stakeholder, we look forward to continued efforts to
implement the LCFS. 

Sincerely,
/
Joel Velasco

_________________________________________________ 
Joel 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  
www.unica.com.br