Over 100 of the Nation’s Top Scientists Call on CA Air Board to Eliminate Biases in the Proposed Low Carbon Fuel Standard
Group Acknowledges Common Goal of Producing Sustainable Alternative Fuels and Protecting Forests, But Says Current Proposal Tilts Playing Field in Favor of Fossil Fuels
Go here to see the letter:
http://www.arb.ca.gov/lists/lcfs-general-ws/28-phd_lcfs_mar09.pdf
The letter recommends that the State Board adopt an LCFS regulation based on direct carbon effects, or those emissions directly attributable to the production and use of the particular fuel. The model used to determine these effects is well-grounded and peer-reviewed, and for biofuel includes the land conversion needed to produce biofuel feedstock.
“A fundamental principle of any comparative carbon lifecycle analysis, and of a performance standard in general, is that all fuels are judged through the same lens,” said Dr.
The scientists, who express their personal beliefs in the letter but conduct research at some of the most prestigious laboratories in the country, outlined two fundamental problems with the proposed LCFS. On the one hand, they challenge the science of indirect land use change, calling it “controversial” and in its “nascent stage” with “clear omissions relative to the real world.” On the other hand, they criticize the selective enforcement of indirect effects against biofuels only, saying, “[e]nforcing different compliance metrics against different fuels is the equivalent of picking winners and losers, which is in direct conflict with the ambition of the LCFS.”
“No level of certainty justifies asymmetrical enforcement of indirect effects,” continued Dr. Simmons. “What the current proposal basically says is that using more biofuel will have ripple effects in the economic marketplace but using more petroleum, natural gas or electricity to power our cars and trucks will have zero ripple effects in the marketplace, ” he added, “which is, of course, not the case.”
Some of the signatories are working on technologies to accelerate the commercialization of advanced biofuels from alternative crops and waste materials. They acknowledge the need to protect pristine lands and forests from unsustainable commercial development, but say the current asymmetrical treatment of biofuels will only undercut efforts to make biofuels more sustainable and less land-intensive.
“We do not think that enforcing an additional and highly uncertain carbon metric on biofuels will save a single acre of the rainforest,” said Dr.
“This is the rare case in which a very complicated problem has a simple short term solution,” said Dr.
The California Air Resources Board plans to submit the final rule to the State Board in late April, and will be releasing a completed initial plan by the end of the week.
Again, the entire letter can be read here:
http://www.arb.ca.gov/lists/lcfs-general-ws/28-phd_lcfs_mar09.pdf
The California Air Resources Board’s LCFS page. http://www.arb.ca.gov/fuels/lcfs/lcfs.htm
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