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Comment 4 for Low Carbon Fuel Standard (lcfs09) - 15-2.

First NameCharles
Last NameAlexander
Email Addresssushibar@excite.com
Affiliationnone
SubjectDifferences of incentivisation between Table 5 on pg. 44 & Table 6 on pg.s 48-49
Comment
Now, Table 6 on pages 48-49 of the Modified Proposed Regulation 
Order give carbon intensity values for corn ethanol that would 
lead some to believe some forms of it marginally superior to 
gasoline.  By contrast, the selfsame table gives carbon values 
for electricity that are in excess of that for standard 
gasoline.  

By contrast, Table 5 on page 44 gives an Energy Economy Ratio  
for electricity that is thrice that for all forms of ethanol.  

Table 6 tends to favor some forms of corn ethanol over 
electricity.  

Table 5 tends to favor electricity over all forms of ethanol.  

Thus, there is a conflict of incentivisation between Tables 5 & 
6.  Given all that is known about the indirect land use effects 
of corn ethanol, especially those impacting global food 
commodity prices & the impact of that on the world's poor, the 
idea of incentivising corn ethanol, to any extent, would most 
certainly seem rather repugnant, one would think.  
Interestingly, the carbon intensity values given for electricity 
in Table 6 do not seem reflective of the carbon intensity of 
hydro-power.  

One would well note that big agribusiness lobbying interests are 
simultaneously arguing for incentivising corn ethanol, which 
would most certainly impose inflationary pressures on global 
food commodity prices (thus increasing portfolio valuations for 
food commodity speculators) AND for the creation of a 
Peripheral Canal, which canal is manifestly designed to 
reduce hydro-electric generation capacity by increasing 
reservoir draw down rates at the same time that water is, 
by virtue of said canal, taken away from farms, ranches, towns, 
cities, etc., in all locations north of the Sacramento-San 
Joaquin Delta.  

Why even give the appearance of giving in to THAT by at all 
incentivising corn ethanol, a fuel whose indirect land use 
effects on global food comodity prices & the debate over the 
Peripheral Canal, among other things, can be very 
disasterous, indeed?  Incentivising corn ethanol is a very bad 
idea!!  

Needless to say, the differences of incentivisation between 
Table 5 on page 44 & Table 6 on pages 48-49 need to be 
properly reconciled.  Thank you.  

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Date and Time Comment Was Submitted 2009-10-06 20:21:12

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