RFA calls to remove Low Carbon Fuels Standard
In the US, the Renewable Fuels Association (RFA) has called on California’s Office of Administrative Law (OAL) to reject the Air Resources Board’s (ARB) Low Carbon Fuels Standard (LCFS) rule currently under review.
The RFA has highlighted numerous instances where ARB violated established procedures by failing to properly address stakeholder comments on the LCFS proposal.
‘ARB’s Final Statement of Reasons (FSOR) does not meet California Administrative Procedure Act (APA) requirements because ARB completely failed to respond to significant issues raised in comments on the proposed LCFS submitted by RFA and other stakeholders,’ RFA states.
The RFA has repeatedly challenged the ARB’s highly uncertain modelling predictions that suggest significant greenhouse gas emissions will result from clearing of South American rainforests and other virgin lands in response to increased US ethanol production.
The impact of indirect land use change (ILUC) on ethanol’s overall carbon footprint is dramatic and unfair, RFA says, adding that no other potential fuel source is penalised for indirect effects under ARB rules.
The letter can be found here: http://www.ethanolrfa.org/objects/documents/2733/rfa_lcfs_letter_to_arb_and_oal1__12_15_09.pdf?utm_medium=email&utm_source=Emailmarketingsoftware&utm_content=664888082&utm_campaign=RFALettertoARBandOAL+_+uhlyti&utm_term=here.
The RFA has highlighted numerous instances where ARB violated established procedures by failing to properly address stakeholder comments on the LCFS proposal.
‘ARB’s Final Statement of Reasons (FSOR) does not meet California Administrative Procedure Act (APA) requirements because ARB completely failed to respond to significant issues raised in comments on the proposed LCFS submitted by RFA and other stakeholders,’ RFA states.
The RFA has repeatedly challenged the ARB’s highly uncertain modelling predictions that suggest significant greenhouse gas emissions will result from clearing of South American rainforests and other virgin lands in response to increased US ethanol production.
The impact of indirect land use change (ILUC) on ethanol’s overall carbon footprint is dramatic and unfair, RFA says, adding that no other potential fuel source is penalised for indirect effects under ARB rules.
The letter can be found here: http://www.ethanolrfa.org/objects/documents/2733/rfa_lcfs_letter_to_arb_and_oal1__12_15_09.pdf?utm_medium=email&utm_source=Emailmarketingsoftware&utm_content=664888082&utm_campaign=RFALettertoARBandOAL+_+uhlyti&utm_term=here.
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