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Comment 8 for Low Carbon Fuel Standard - Lifecycle Analysis (lcfs-lifecycle-ws) - 1st Workshop.


First Name: Cal
Last Name: Hodge
Email Address: a2ndopinioninc@aol.com
Affiliation: A 2nd Opinion Inc. for Neste Oil

Subject: Group 1 LCA Land Use Change Comments
Comment:
A 2nd Opinion, Inc.
Clean Fuels & Regulatory Issues

Cal Hodge, President

Dear Anil:

The articles reproduced below illustrate why I enjoy consulting
with Neste oil.  Please add them and this cover email to the
record.

I have known various Neste people since the mid nineties.  I have
observed that they are straight forward practical people who like
to do the right things the right way.  These articles show that
doing the right things the right way starts at the top. Neste Oil
welcomes strict sustainability criteria for biofuels because it is
the right thing to do.  Neste Oil's views on palm oil are well
thought out and constructively address many of the rainforest
concerns that have recently been raised about biofuels. 

For example Neste mentions two examples that should should
eliminate or significantly change the land use change debit
calculated in the UCB spreadsheet.  Increasing yield on the same
land should cause the land use change (LUC) debit to be zero for
the incremental production.  Converting idle land to oil
production should have a much smaller LUC debit than the
rainforest debits calculated in the UCB spreadsheet.  If planting
the oil crop stops the land from eroding into the sea, the
rainforest LUC debit should also approach zero. 

What this boils down to is that LCA is a very complex issue and
that we must be careful to not paint with brushes that are too
wide.  The people who are doing it right deserve to be treated
differently from those that do it wrong.  Our workgroups have to
develop a methodology that encourages best practices.  That makes
our job tougher.  But if we want to reduce carbon emissions we
have to step up and do it.

For A 2nd Opinion, Inc.

Cal Hodge

19 Serenade Pines Place - The Woodlands, TX 77382-2005
Phone: 281-844-4162 FAX: 281-966-6914
Email: A2ndOpinionInc@aol.com

Attachment: www.arb.ca.gov/lists/lcfs-lifecycle-ws/8-013108a2ndopinion.pdf

Original File Name: 013108a2ndopinion.pdf

Date and Time Comment Was Submitted: 2008-02-01 17:46:13



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