| First Name | Blake |
|---|---|
| Last Name | Simmons |
| Email Address | basimmons@lbl.gov |
| Affiliation | |
| Subject | Concerns over selective inclusion of indirect land use change on biofuels |
| Comment | The attached letter outlines the concerns several (111) scientists have over the selective inclusion of an indirect land use change metric on biofuels under the proposed LCFS, and that the model and the science behind indirect land use change is too nascent to be included at the current time. We urge the ARB to develop a fair, robust, and open science- and data-based metric, as well as opening the ARB process to other models and methodologies other than GTAP, to evalaute indirect land use change for all fuels that will be evaluated with the LCFS. |
| Attachment | www.arb.ca.gov/lists/lcfs09/66-28-phd_lcfs_mar09.pdf |
| Original File Name | 28-phd_lcfs_mar09.pdf |
| Date and Time Comment Was Submitted | 2009-04-10 12:14:34 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.