Comment Log Display

Low Carbon Fuel Standard 

CAPCOA supports the goal of the Low Carbon Fuel Standard adopted
by ARB to reduce the carbon intensity of transportation fuels.
However, to ensure that local and regional air quality impacts are
not exacerbated in the process and that energy reduction goals are
actually realized, extensive analysis will be required prior to
development of the implementing regulation, including the
following: 

1.  Evaluation of the toxic and criteria pollutant impacts of
biofuels to ensure that public health is not compromised in
implementing this measure. 

2.  Analysis of the impact of biofuels on broader societal issues
and how these might affect implementation effectiveness, such as
the potential for the regulation to create “domino” effects on
grains and crops that ultimately affect food availability and cost.


3.  Development of better tools to assess and audit land use
implications of the various strategies, such as potential
conversion of pastures, rainforests and other existing carbon sinks
to fuel production and how that will affect the global carbon
balance. 

4.  Analysis of the potential to increase light-duty vehicle
dieselization if a market-based, averaging mechanism for fuel
carbon content is used to provide regulatory flexibility.