| Comment | The attached letter outlines the concerns several (111) scientists
have over the selective inclusion of an indirect land use change
metric on biofuels under the proposed LCFS, and that the model and
the science behind indirect land use change is too nascent to be
included at the current time.
We urge the ARB to develop a fair, robust, and open science- and
data-based metric, as well as opening the ARB process to other
models and methodologies other than GTAP, to evalaute indirect land
use change for all fuels that will be evaluated with the LCFS.
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