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I write to call your attention to a serious risk that proposed
revisions to the Low Carbon Fuel Standard currently being developed
by CARB staff could have the unintended consequence of increasing
greenhouse gas emissions, rather than lowering them, by driving a
large increase in consumption of crop-based biofuels that result in
greater emissions than petroleum-based transportation fuels. To
prevent this perverse outcome, I urge CARB to establish a cap on
the use of crop-based biofuels for LCFS compliance at 2022 levels
while it revises its approach to calculating the Carbon Intensity
of such fuels to properly account for their impacts on land use.

Please see attachment for further details.