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Comment 15 for LCFS Program Review Advisory Panel (2011) (lcfsadvisorypanel-ws) - 4th Workshop.


First Name: Charles
Last Name: Alexander
Email Address: sushibar@excite.com
Affiliation:

Subject: In re, (inter alia) Ultra-low carbon fuel (hydro-electric dam generated electricity)
Comment:
Thank you for the opportunity, herenow, to provide Comment on "Low
Carbon Fuel Standard 2011 Program Review Report."  
Now, at various places in the "Low Carbon Fuel Standard 2011
Program Review Report; Working Draft, Version 1" (herein after
referred to as "the Report") optimism is expressed that, as
standards become progressively more stringent, that the fact of it
will spur investment in research into and development, production,
distribution, & (ultimately) retail sales of ultra-low carbon
fuels.  Recent events up in Siskiyou County, among other things,
should temper some of that optimism.  For instance, there are those
endeavoring to remove several hyrdo-electric dams in Siskiyou
County, and another in eastern Shasta County.  Additionally, these
same entities have been endeavoring to abrogate (or at least
derogate) the water rights of farmers & ranchers living in Siskiyou
County.  If these entities ultimately succeed, they will remove
from the electricity grid in California a number of different
ULTRA-LOW CARBON sources of electricity.  Additionally, dam removal
will remove water availability from senior water rights holders,
including many lesser-capitalised farmers & ranchers.  Operation,
permitation, maintenance, etc. of the pumps, etc. that would
replace all those dams (for the water rights holders) would be
significantly more expensive than the use dam water.  This is
expected to cause at least some lesser-capitalised water rights
holders to remove their lands from availability for to cultivate
crops.  This, in turn, will cause inflationary pressures brought to
bear upon food prices (already) by biofuel production & mandate to
be even WORSE.  And this in addition to the fact that the
cultivation of biofuel feedstock requires land.  And when land is
removed from crop-availability, this brings inflationary pressures
to bear BOTH on the price of food & on the price of biofuel
feedstock.  Pumps require fuel.  When dams are removed, the carbon
index (CI) of electricity in California will inevitably increase! 
It's a simple matter of mathematics.  Compliance with LCFS targets
will be more difficult!  Already, carbon net deficits are expected
to be generated by approximately 2017.  Removal of hydro-dams & of
irrigation dams will make that problem even worse.  Under Executive
Order S-06-06, by 2020, 40% of all biofuels used in California will
have to be produced in California (see pg. 30 of Report, inter
alia).  How is that to happen when hydro-dams & irrigation dams are
proposed to be removed?  Incidentally, when a dam is removed, all
the sediment that settles at the base of it is released downstream,
killing many fish (especially those endangered).  And some of that
sediment can be expected to deposit in downstream spawning beds,
thus exacting long-term toll on fish populations.  Is this at all
in keeping with the ideas of Sustainability?  No.  It is not!  On
pg.s 59 & 60 of the Report, it was noted that, during a 6 yr.
survey period between 2004 & 2010, increased crop-based biofuel
production has contributed significantly to increases in extreme
poverty, particularly in South Asia & in Sub-Saharan Africa, not to
mention increases in hunger-related diseases & tthus to decreases
in life expectancies in those affected populations.  And when
crop-land in Northern California is taken out of circulation, the
problem can get even WORSE, because yet additional inflationary
pressures are thus brought to bear upon both food commodity &
biofuel feedstock commodity prices.  Fuels like "algae-gasoline" &
"algae-diesel" are yet many years away from large-scale retail
availability.  Also, butanol is still not yet available for retail.
 So what is left is that ultra-low carbon electricity is being
proposed to be taken off the market, whilst next generation
low-carbon fuels like butanol, "algae-gasoline," & "algae-diesel"
are still a number of years yet into the future.  First generation
biofuels, such as corn-ethanol, whose CI is the same as that for
gasoline (BTW), production of which 1st Gen biofuels has imposed
inflationary pressures on food-commodity prices, end up in the
line-up by default.  But is THIS the way to move forward with a
LCFS?  How is latter-year compliance supposed to be achieved under
those conditions?  The only answer is that of ultra-low carbon
electricity!  And that means hydro-dams!  They must not be removed!
 Calculate separately the CI of electricity generated by hydro-dam
from that of electricity State-wide & there is no contest. 
Hydro-dams are an extremely low-carbon way of generating
electricity!  Hydro-dam generated electricity is an already
existing ultra low carbon fuel!  Why take it off the market?  And
if existing crop land is allowed to remain in circulation,
inflationary pressures that would have (by the crop-lands being
taken out of circulation) been brought to bear upon both
food-commodity & biofuel feedstock commodity prices are thus NOT
added to the inflationary pressures that biofuels already bring to
bear upon food-commodity prices.  But one thing, inter alia, is
essential.  The dams must NOT be removed!!  It would behoove ARB, &
anyone reading this, to contact all relevant State & Federal
agencies & urge them to save the hydro-dams.  

Thank you.  

P.S., 
On a positive note, it is good that, in several places in the
Report, there is mention of inclusion of indirect land use effects
in calculation of CI values.  This must remain an indelibile part
of the LCFS!  Thank you.  

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Date and Time Comment Was Submitted: 2011-11-16 20:39:56



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