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Comment #5 for Public Workshop to Discuss Potential Changes to the Low Carbon Fuel Standard
(lcfs-wkshp-jul22-ws) - 1st Workshop

First Name: Charles
Last Name: Davidson
Email Address: charlesdavidson@me.com
AffiliationRodeo Citizens Association
SubjectCARB's LCSF biofuel accrediting arbitrarily excludes tank-to-wheel CO2 emissions
Comment

CARB's LCSF biofuel accrediting arbitrarily excludes tank-to-wheel carbon dioxide emissions 

 

California Air Resources Board’s (CARB’s) current Low Carbon Fuel Standard (LCFS) should no longer regulate the exclusion of tank-to-wheel carbon dioxide emissions in their calculation of the total carbon intensity of refinery renewable diesel and biodiesel in their well-to-wheel carbon intensity assessment (or the tank-to-wake CO2 for SAF). Inclusion of tank-to-wheel emissions for Renewable Diesel (and tank-to-wake CO2 emissions for SAF) is consistent with California’s climate goals and AB 32, the California Global Warming Solutions Act of 2006. The tank-to-wheel assessment for agricultural-based biofuels should be based on the same CO2 measurement methods as petroleum fuels. 

 

AB 32 requires “in law, a sharp reduction of greenhouse gas (GHG) emissions…[which] set the stage for its transition to a sustainable, low-carbon future”. For purposes of greenhouse gas emissions reduction, under the LCFS for transportation fuels and consistent with AB32, only accurate amounts of CO2 emissions should be considered when providing GHG reduction credits.

 

However, CARB’s LCFS greenhouse gas document states that “the COemitted from vehicles during biofuel combustion is considered carbon neutral, in accordance with IPCC and U.S. EPA GHG inventory guidelines, as the carbon released was uptaken from the atmosphere within a short timeframe by the plant that produced the oil. A small amount of emissions, less than 1 g/MJ, result from the GHGs (methane and nitrous oxide) that form during biodiesel combustion.” [Italics mine.]

 

[LCFS Basics with Notes - California Air Resources Board. https://ww2.arb.ca.gov/sites/default/files/2020-09/basics-notes.pdf]

 

Simply because the CO2 consumed by plant growth is combusted during biofuel usage does not negate the fact that the likely use of massive, yearly biofuel feedstock production on agriculture lands results in the massive loss of natural carbon sequestration pathways on otherwise undeveloped lands (in addition to the carbon intensive depletion of soils in industrialized forced biofuel feedstock agriculture).

 

Researchers in Mildrexler et al “analyzed forest inventory data collected on 3,335 plots and found that large trees play a major role in the accumulated carbon stock of these forests. Tree AGC (kg) increases sharply with tree diameter…among five dominant tree species. Large trees accounted for 2.0 to 3.7% of all stems…among five tree species; but held 33 to 46% of the total AGC stored by each species. Pooled across the five dominant species, large trees accounted for 3% of the 636,520 trees occurring on the inventory plots but stored 42% of the total AGC. A recently proposed large-scale vegetation management project that involved widespread harvest of large trees, mostly grand fir, would have removed 44% of the AGC stored in these large-diameter trees, and released a large amount of carbon dioxide to the atmosphere.”

 

Large Trees Dominate Carbon Storage in Forests East of the Cascade Crest in the United States Pacific Northwest Front. For. Glob. Change; Forest ManagementDavid J. Mildrexler et al. (05 November 2020) https://www.frontiersin.org/articles/10.3389/ffgc.2020.594274/full

 

The above facts strongly argue for a policy change by CARB, that when the agency decides the greenhouse gas credit worthiness of a transportation fuel, the Low Carbon Fuel Standard should no longer arbitrarily regulate the exclusion of tank-to-wheel carbon dioxide emissions in their calculation of the total carbon intensity of renewable diesel and biodiesel (or the tank-to-wake CO2 for SAF). 

Attachment www.arb.ca.gov/lists/com-attach/8-lcfs-wkshp-jul22-ws-UDMHYANwADFQCVVn.docx

Original File Name: CARB 2022 Scoping Plan Public Comments %22-5%22%22%22.docx

Date and Time Comment Was Submitted: 2022-07-25 18:44:37


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