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Comment 5 for Low Carbon Fuel Standard (lcfs09) - 45 Day.


First Name: Richard
Last Name: Ottinger
Email Address: rottinger@law.pace.edu
Affiliation: Dean Emeritus, Pace Law School

Subject: Land Use Valuation for LCFS
Comment:
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


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Date and Time Comment Was Submitted: 2009-03-19 07:27:39



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