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Comment 5 for Low Carbon Fuel Standard (lcfs09) - 45 Day.
First Name: Richard
Last Name: Ottinger
Email Address: firstname.lastname@example.org
Affiliation: Dean Emeritus, Pace Law School
Subject: Land Use Valuation for LCFS
I strongly endorse the views expressed in the letter to The ARB submitted by Carol Werner, Executive Director of the Environmental and Energy Study Institute. While I am Chair of the EESI Board of Directors, I also am a Former Member of Congress (1964-1985), chairing its Energy, Conservation & Power Subcommittee; Faculty Member of Pace Law School and Chair of its Energy and Climate Center; and Chair of the Energy and Climate Specialty Group of the IUCN Commission on Environmental Law. The views expressed by Ms. Werner on the unreliability of land use valuations in determining the costs and benefits of bioenergy production are sound. There is no sound way of knowing what value to be placed on the indirect effects of land use on biofuels production in light of the inability to ascertain the effects of other land use demands. Also it is unwise to single out biofuels for such a valuation, ignoring the land use consequences of fossil fuel, nuclear and other energy resources; even solar and wind projects have land use consequences, equally unmeasurable. Bioenergy unfortunately has achieved strong negative bias from many environmental organizations because of the ill food effects of US corn crop as a biofuel feedstock and the Indonesian castrophy of using deforested areas and peat bog destructions to plant palm plantations for biodiesel. Standards need to be adopted to prevent such practices and are being developed, most particularly by the Roundtable on Sustainable Biofuels of the Ecole Polytecnique de Lausanne. But putting a false value on land use just for Bioenergy, practically making it unmarketable, is bad energy and climate policy. Respectfully submitted Richard Ottinger Dean Emeritus Pace Law School
Original File Name:
Date and Time Comment Was Submitted: 2009-03-19 07:27:39
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