First Name | Kirk |
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Last Name | Leonard |
Email Address | kirkleon@spiritone.com |
Affiliation | |
Subject | ILUC assessments are not possible today |
Comment | I am a latecomer to these deliberations, a participant in the Roundtable on Sustainable Biofuels. I have no knowledge of the models CARB may be using for LCFS indirect land use change assessments on biofuels but I have some considerations to suggest. The biofuels industry is greatly sensitized to the use of food-producing lands for biofuels. It can be expected that many land use changes associated with biofuels will involve the use of existing agricultural lands that are either idled or damaged. Additionally, biofuel crops can be grown on marginal lands, which may involve land use changes. Are there carbon sequestration credits for use of damaged or marginal lands included? These uses are likely to enhance the lands’ carbon capacity. Are there carbon costs allocated to biofuel crops as a result of crop rotations? How are you distinguishing between a rotation and a new land use? Further, if new ag lands aren’t burned or plowed, there will be little carbon loss, and if the land is cultivated well, carbon capacity will increase appreciably, quickly and over time. Is this information included? It seems to me to be another possibly significant set of carbon credits. How are your sorting out these kinds of land use changes? The largest concern here seems to be deforestation. To my knowledge, none has occurred yet solely for biofuel production, internationally. Finally, land use change carbon impacts depend on site-specific factors – current use, soil organic content, how the land was prepared and subsequently managed. Are these factors incorporated in your models? No one I am aware of has been able to account for these factors completely. While I agree with the goal of including indirect land use changes in LCFS, we don’t have the data or the current collection capacity required for an appropriate or accurate assessment. Future study of indirect land use impacts associated with biofuels, and all other energy resources, is prudent. Today, however, I believe the best we can do is an assessment of their direct production and use effects. The Board should acknowledge possible indirect land use change effects associated with biofuels in setting a LCFS and urge further study. Indirect land use effects as currently developed should not be included. Throughout the history of the petroleum industry, vast urban and economic development, there has never been consideration of carbon emission effects. Why have renewable low carbon fuels suddenly made land use change this important? |
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Date and Time Comment Was Submitted | 2009-04-16 14:03:48 |
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