Comment Log Display

Dear CARB Officials : 
The attached document titled , " Critique of Transparency in CARB
LCFS Methods " , focuses on the inadequacy of the LCFS methods
proposed for corn grain ethanol.  This document was previously sent
to you by its authors, including Ken Cassman and Adam Liska.  The
Nebraska Ethanol Board, a state agency established in 1971, concurs
with the comments previously provided by Dr. Cassman.  Our support
of this position is based in part on the fact that far more precise
actual operating data from ethanol plants is readily available from
state regulatory agencies in several states including Nebraska and
Iowa.  The decision to not include the more recent data, which
reports actual operating data and emissions, is not a defensible
position for state rulemaking agencies in our opinion.  To base a
compliance standard on outdated "default" data is simply not an
approach that encourages or supports "best practices".  As a
result, real world environmental impacts will ultimately be
discouraged rather than embraced.  The proposed CARB LCFS does not
reflect the best science or the best compliance matrix under which
to measure or encourage the best environmental outcomes.  Data
currently available can and should be used in an effort to promote
the best results if transportation carbon reduction is the goal of
a proposed LCFS.
 
Submitted by:
Todd C. Sneller
Administrator
Nebraska Ethanol Board