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Comment 24 for Comments for the LCFS Method 2A2B applications (lcfs2a2bcomments-ws) - 8th Workshop.


First Name: Elias
Last Name: Marvinney
Email Address: emarvinney@ucdavis.edu
Affiliation: UC Davis

Subject: prevention of perverse incentives with forest residue use
Comment:
To whom it may concern:

While the general goal of this application seems reasonable and
even supportive of statewide sustainability goals, I believe that
there is an unacceptable risk of creating perverse incentives that
may promote deforestation when incentives to utilize forest residue
are given. I strongly urge ARB to reconsider certification of fuels
from forest residues until the agency has the appropriate capacity
and authority to monitor and verify that it is not causing
deforestation or loss of forest carbon stock.

Best regards,
Elias Marvinney 

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Date and Time Comment Was Submitted: 2015-12-17 18:21:40



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