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Comment 51 for Low Carbon Fuel Standard (lcfs09) - 45 Day.
First Name: Chris
Last Name: Hagerbaumer
Email Address: firstname.lastname@example.org
Affiliation: Oregon Environmental Council
Subject: comments on LCFS proposed regulation
The Oregon Environmental Council (OEC) greatly appreciates CARB's hard work developing regulations to establish a Low-Carbon Fuel Standard. The LCFS is an innovative and important approach to tackling global warming, and we are strongly supportive of it. Lest you wonder why an out-of-state organization is interested in CARB regulations, you should know that the Oregon Department of Environmental Quality will hopefully be given the authority by the Oregon Legislature this session to undertake rulemaking to establish a LCFS in Oregon. For many years, OEC has worked to support the development and application of a variety of technologies and strategies to reduce greenhouse gas emissions from the transportation sector, including the production of regional, sustainably produced, low-carbon biofuels. OEC is advocating for a LCFS in Oregon that will harmonize with California’s, and we want to make sure that LCFS implementation is accurate and fair. The beauty of a LCFS is that it is performance-based, allowing affected companies to meet the standard through a variety of means and avoiding premature conclusions about the “right” technology. Encouraging development of the right technologies hinges upon an even playing field. We are worried that CARB is creating an uneven playing field by choosing to account for the potential indirect carbon effects of biofuels, while not accounting for the potential indirect carbon effects of other fuels. Indeed, other fuels have indirect carbon effects: for example, the use of natural gas as a vehicle fuel means less natural gas will be available for stationary energy needs, potentially leading to the development of more coal-fired power plants. Likewise, the use of electricity for our transportation needs may increase demand on electricity and push us to dirtier fuels like coal. Likewise, oil companies are turning to the most polluting, most carbon-intensive means of producing oil – they are disturbing vast tracts of land and harming ecosystems while extracting oil from tar sands. What is the indirect effect of relying on a resource that has peaked? What is the indirect effect of increasing petroleum prices on food prices and the resulting increase of food prices on land use change? In your draft regulation, you indicate that you believe other fuels do not have indirect carbon effects. In order for us to be comfortable with that statement, we need to see your analysis. The potential indirect carbon impacts of fuels besides biofuels need to be modeled by CARB, as well. We believe it is prudent to follow the example of the EU and the recommendations of the 111 scientists who wrote to you on this subject who have called for an initial LCFS based on direct emissions while we take the time necessary to thoroughly assess indirect effects for all fuels. An even playing field is crucial to responsible implementation of a LCFS. Thank you very much for your consideration.
Original File Name:
Date and Time Comment Was Submitted: 2009-04-08 16:19:42
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