Comment Log Display
Below is the comment you selected to display.
Comment 15 for Low Carbon Fuel Standard - General (lcfs-general-ws) - 1st Workshop.
First Name: Patricia
Last Name: Monahan
Email Address: pmonahan@ucsusa.org
Affiliation: Union of Concerned Scientists
Subject: Carbon accounting using scientific principles
Comment:
Attached are UCS's comments on the October LCFS draft regulation, specifically on the question of how to appropriately account for carbon emissions over time. We recommend that CARB consider utilizing scientific rather than economic principles to account for carbon. Bottom line: accounting for the fact that carbon continues to reside in the atmosphere and has a radiative forcing effect for decades worsens the case for corn ethanol and for any biofuel with indirect land use effects.
Attachment: www.arb.ca.gov/lists/lcfs-general-ws/21-ucs_comments_nov_2008.pdf
Original File Name: UCS comments_Nov 2008.pdf
Date and Time Comment Was Submitted: 2008-11-14 17:18:05
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.
