Comment Log Display

The Oregon Environmental Council (OEC) greatly appreciates CARB's
hard work developing regulations to establish a Low-Carbon Fuel
Standard. The LCFS is an innovative and important approach to
tackling global warming, and we are strongly supportive of it.

Lest you wonder why an out-of-state organization is interested in
CARB regulations, you should know that the Oregon Department of
Environmental Quality will hopefully be given the authority by the
Oregon Legislature this session to undertake rulemaking to
establish a LCFS in Oregon. 

For many years, OEC has worked to support the development and
application of a variety of technologies and strategies to reduce
greenhouse gas emissions from the transportation sector, including
the production of regional, sustainably produced, low-carbon
biofuels. 

OEC is advocating for a LCFS in Oregon that will harmonize with
California’s, and we want to make sure that LCFS implementation is
accurate and fair. 

The beauty of a LCFS is that it is performance-based, allowing
affected companies to meet the standard through a variety of means
and avoiding premature conclusions about the “right” technology.
Encouraging development of the right technologies hinges upon an
even playing field. We are worried that CARB is creating an uneven
playing field by choosing to account for the potential indirect
carbon effects of biofuels, while not accounting for the potential
indirect carbon effects of other fuels. 

Indeed, other fuels have indirect carbon effects: for example, the
use of natural gas as a vehicle fuel means less natural gas will be
available for stationary energy needs, potentially leading to the
development of more coal-fired power plants. Likewise, the use of
electricity for our transportation needs may increase demand on
electricity and push us to dirtier fuels like coal. 

Likewise, oil companies are turning to the most polluting, most
carbon-intensive means of producing oil – they are disturbing vast
tracts of land and harming ecosystems while extracting oil from tar
sands. What is the indirect effect of relying on a resource that
has peaked? What is the indirect effect of increasing petroleum
prices on food prices and the resulting increase of food prices on
land use change?  

In your draft regulation, you indicate that you believe other
fuels do not have indirect carbon effects. In order for us to be
comfortable with that statement, we need to see your analysis. The
potential indirect carbon impacts of fuels besides biofuels need to
be modeled by CARB, as well. 

We believe it is prudent to follow the example of the EU and the
recommendations of the 111 scientists who wrote to you on this
subject who have called for an initial LCFS based on direct
emissions while we take the time necessary to thoroughly assess
indirect effects for all fuels. 

An even playing field is crucial to responsible implementation of
a LCFS.

Thank you very much for your consideration.