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Comment 15 for Comments for the LCFS Method 2A2B applications (lcfs2a2bcomments-ws) - 3rd Workshop.

First Name: sydney
Last Name: bacchus
Email Address:

Subject: Public Comments for Application 69 for pathways for the Low Carbon Fuel Standard (LCFS)
My comments are provided as "Public Comments" for application 69
for pathways for the Low Carbon Fuel Standard (LCFS), from the
following link:

My comments identify actual or methodological errors in Neste Oil
for renewable diesel (RD) produced at its plant in Singapore from
(a) North American tallow and (b) Southeast Asian fish oil.

Application 69 proposes to use "Southeast Asian Fish Oil" as
"renewable diesel" (RD).
Fish oil is the most valuable source of Omega 3 fatty acids, which
are essential for human health.  Fish not only provide essential
food for humans, but also for countless other animals in the food

This application ignores the well-established scientific fact that
natural fisheries are collapsing worldwide and industrial fish
farming is contributing to this global collapse.
Therefore, "fish oil" from ANY source cannot be considered anymore
"renewable" than whale oil for lamps in colonial days.

This application also fails to consider the fact that this
NON-renewable fish oil and oil from American tallow would be
manufactured thousands of miles away in Singapore and would NOT be
transported telepathically to California.
Neither the air quality contamination from the manufacturing of
those oils in Singapore or the transportation of those oils,
shipped by ocean tanker an estimated 7,741 nautical miles, was
considered in the application.

Please see the recent report below regarding the air pollution in
China from this type of "out-sourced" industry, particularly the
section on "Outsourcing blowback: Chinese air pollution drifts to
the U.S." which states:
'The levels of pollution from China are so high that the air
pollution reaches the United States within six days, adding
significant pollution to the West Coast, which has been registered
by the EPA."

Therefore, this application fails to meet the definition of
"renewable" and fails to reduce air quality pollution in California
and should be denied.

Sydney Bacchus, Ph.D.


Beijing air pollution reaches crisis levels; can China survive its
toxic environment? 
Tuesday, January 28, 2014 by: Thomas Henry

Learn more:

(NaturalNews) China is the world's worst industrial polluter,
spewing tons of toxins derived from man-made production into the
air, soil and water at a steady rate. It has refused to comply with
the same standards adopted by other leading nations of the world.

And the level of pollutants is starting to catch up with China's
residents, who have to breath it. Recent weeks have seen
declarations of "extremely dangerous pollution" in Beijing, with
particulate matter reaching more than two dozen times the level
considered safe for airborne toxins.

Workers and commuters commonly wear face masks to combat the often
pungent odors and dust, while many suffer from chronic coughs and
irritation in their airways and nasal passages.

The smog has reportedly worsened in the last couple of years,
obscuring the skyline in major cities and severely limiting
visibility. This toxins further compound in the winter with the
heavy use of coal for heating and the often stale air.

While the World Health Organization (WHO) considers fine particles
(PM2.5) safe below 25 micrograms, Beijing monitoring stations have
recently recorded levels between 350-500 micrograms and as high as
671 micrograms. In Harbin, the tenth most populous city in China,
which is located in the far northeast of the country, PM2.5 levels
soared as high as 1,000 micrograms.

A Harvard study published in 2013 found that China's refusal to
curb air pollution was contributing to shorter lifespans among its
population, particularly in the north, including Beijing. The
almost absurd levels of total suspended particulates just from
using coal to heat homes has shaved off a calculated 2.5
  billion years of life
expectancy for the 500 million residents of northern China,
depriving individuals of an estimated 5.5 years of life.

Outsourcing blowback: Chinese air pollution drifts to the U.S.
Conventional wisdom has touted that outsourcing the manufacture of
cheap goods to China and other sources of cheap labor would hold
the added benefit of cutting down on pollution
  in the United States
(with fewer at work in American factories). But that, too, has
bitten back.

 A fresh study conducted by the University of Washington found that
smog and other airborne pollution from Chinese factories was
creeping back to the U.S., along with infinite tons of imported
goods. A full 21% of China's industrial pollution comes from
manufacturing exports for the United States, bringing to full
circle a new form of literal blowback.

The study's authors wrote, "Outsourcing production to China does
not always relieve consumers in the United States - or, for that
matter, many countries in the Northern Hemisphere - from the
environmental impacts of air pollution

The levels of pollution from China are so high that the air
pollution reaches the United States within six days, adding
significant pollution to the West Coast, which has been registered
by the EPA.

The study found, "On a daily basis, the export-related Chinese
pollution contributed, at a maximum, 12-24% of sulfate
concentrations over the western United States."

Heavy metal contamination in foods from China
Outsourcing also means that a great deal of the food consumed in
America is produced in China - where the pollution also includes
high levels of heavy metals. Currently, China
  ranks as the third largest
source of imported food in the United States, though even the FDA
is unsettled enough to turn away hundreds of batches of
contaminated food each year.

Everything from packaged meals and canned food
  to USDA-certified Organic
produce ships to the U.S. in massive quantities on a regular basis.
Previous exposes by Natural News and throughout the media have
shown how much of this food is produced with standards considered
unacceptable here in the States, and that the most populous country
is also turning out some of the most contaminated foods in the
world, frequently tainted with toxins including lead, cadmium,
mercury, arsenic and even uranium.

In December 2013 - after a 2006-2009 soil survey was finally made
public - the deputy minister of China's Ministry of Land and
Resources declared that some 3.3 million hectares of farmland in
central China was so polluted with heavy metals and industrial
contamination that it could not be used to grow crops anymore.
Cadmium was the chief concern for soil pollution. Additionally,
some 60% of the groundwater used for drinking in Chinese cities is
considered "dangerously polluted" with heavy metals, while the
Asian country is notorious for its severely polluted rivers filled
with industrial waste.

And again, all of this trickles back to the United States on a
continuous basis.

Natural News and the Consumer Wellness Center have been running
tests for heavy metal content in many popular food sources
(particular to lot numbers). Check out some of the results (visit
site here:
 ) for a better understanding of
what's really in your food and what kind of heavy metal burden your
diet could be placing on your body.

The scientific literature already raises alarm over
Chinese-produced foods. Just one study from 2011 published in the
Journal of the Science of Food and Agriculture on wheat grown in
northwest China found very high levels of cadmium and lead,
demonstrating, according to the authors, that food remains "an
important avenue for toxic metals entering the human food chain."

Beyond just China's melamine infant formula scandal, an
electrothermal atomic absorption analysis conducted by the
University of Valencia found that all 29 commercially available
infant cereals it tested were contaminated with both cadmium and
lead, creating a chronic toxicity issue from foreign-produced

Sources for this article include:

Learn more:


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Date and Time Comment Was Submitted: 2014-01-31 18:01:54

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