Comment Log Display

Dear CARB

Briefly read the rule.  pretty bad rule result from a lot of time
spent discussing core issues and no consideration of any of the
comments we made in your documents.

i hope you are prepared to defend the science of your indirect
land use change as applied to brazilian sugar cane in a WTO lawsuit
as it appears likely that Brazil will take that action in the USA
and Europe.  In my view, based on review of the science of a
correlation between Amazon destruction and sugar cane production,
you have a very weak case.

it is also unfortunate that you were unwilling to look at
integrated strategies of forest preservation with carbon credits to
really solve the deforestation as opposed to this scientific
hatchet job to appease a political base.  if you want to really
solve this problem, then address this in cap and trade and provide
real funding for permanent preservation through avoided
deforestation credits.  The likelihood that you will have no
national cap and trade this year is a real challenge for you now. 
however, based on the steps to date, i find it unlikely that you
could solve Amazon destruction with a California cap and trade as
this would also fall victim to politics.  

while there is some correlation in Indonesia and jungle
destruction so that indirect land use change can be more clearly
linked there, this is no reason not to be better in your scientific
analysis of policy issues and in trying to make a universal global
link between issues. Even in Indonesia there is a backlog of 7
million hectares of land not being used that was supposed to be cut
to clear land for palm plantations.  Forests are being cut to sell
trees or charcoal!!!!!!!!!!! Brazil land can be bought dirt cheap
in the Northeast ($100 or less per acre).  the sale of land for
sugar cane production in Sao Paulo and land for biofuel feestocks
is not what is driving forest destruction.  It is logging, charcoal
and ranching, and ranch expansion is occurring after logging and
charcoal production have destroyed the forests and usually with
lots of corruption and free land thrown in.  In addition, this is
no longer happening.  you cannot get free land from
 INCRA anymore in the legal Amazon and there is now serious
enforcement of laws in Brazil.  you cannot grow either sugar cane
or soybeans in the Amazon.  The country has committed to 80% cut in
deforestation.  Brazil has made real commitments to climate change
reductions.  And this is how you treat them?  clearly a disconnect.
 

it is also unfortunate that California imports large amounts of
tropical hardwoods in the form of furniture but has no mechanism to
address the land use change impacts of this purchase and yet is
trying to make a link to the forest destruction with biofuels. 
rather ridiculous from a policy standpoint.  We would suggest you
join an effort to impose global tarrifs on true reasons for
deforestation and carbon emissions as part of an Climate Change
accord that could get meaningful climate emission cuts from China.
this would involve WTO enforced tarrifs on all products sold in
international commerce that have a significant impact on climate
change (wood, steel, cement, oil, etc.)

it is also really unfortunate that you stop at the tank instead of
the wheels in assessing low carbon fuels and fail to incorporate
fuel additives in your analysis of options to reduce carbon
emissions.  bad public policy decision.  it will be interesting to
see how you will deal with other groups taking this policy
direction like British Columbia and achieving real carbon emission
reductions while you get nowhere.  It is now likely you will not
get any further than the RFS 2 mandatory requirements in the
implementation of the low carbon fuel rule since you claim there is
little carbon benefit because of the poor science of indirect land
use change and your acceptance of this science in implementing this
regulation.

finally, the lack of indirect land use change being applied to
petroleum is a real distorted view of reality in light of the
environmental destruction from major oils spills (Alaska still has
not recovered from its spill and damage in France was severe) and
Iraq (oil war correlation is much stronger than sugar cane and
Amazon) and jis rather disturbing given that this is against all
rules of equal treatment that are in ARB's code of conduct.  

but then this is not an unexpected result.  the conclusions for
how to proceed were made in 2008 and the rest has all been window
dressing.

sincerely
bill wason