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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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