Comment Log Display

I'm Dan Lashof, US Director of the World Resources Institute. I
have been a strong supporter of the LCFS program for many years,
but today I'm profoundly conflicted. Chair Randolph made a
compelling case for the LCFS in her opening comments. At the same
time, I'm alarmed by the rapid increase in the use of crop-based
Renewable Diesel in the last several years. 

The record for this rulemaking is chock full of detailed comments
showing that crop-based biofuels are worse for the climate than
petroleum fuels when the opportunity cost of using prime farmland
for fuel production is accounted for. These comments include a
devastating critique of the GTAP model currently used by CARB to
calculate indirect land-use change emissions, written by the Chair
of the Yale economics department.

The debate on ILUC can seem esoteric, but it comes down to a very
simple question: Does it make any sense to turn food crops into
fuel? The answer to this question is clearly NO, given the impact
of dedicating millions of acres of prime farmland to fuel
production on food prices and global deforestation. 

The proposed rule nominally includes a 20% credit limit on some
virgin vegetable oils. This is a step in the right direction, but
its impact is questionable at best given that current producers are
grandfathered and that RD volumes above the cap are still credited
at the CI of the emissions target, rather than the CI of fossil
diesel.

The proposed resolution also calls for a workshop on ILUC modeling.
Given all the workshops CARB has already hosted and the detailed
comments in the record, this frankly looks like a box-checking
exercise. 

I urge the Board to adopt a resolution that specifically calls on
staff to replace its current approach to calculating ILUC with one
that is empirically grounded and scientifically sound. I also urge
the Board to call for an effective cap on crop-based fuels followed
by a phase out by 2030. 

As noted in the staff presentation, what CARB does has enormous
influence on other states and countries. Please send a clear
message that turning food into fuel is not an effective or
acceptable climate policy.

Thank you.