The California Air Resources Board (CARB) is set to vote on the Low Carbon Fuels Standard (LCFS) on April 23-24, 2009. This first of its kind bill was designed to reduce the carbon intensity of all transportation fuels in California 10 percent by 2020. Many states, as well as the federal government, are watching the outcome very closely as they consider adopting similar bills.

In preparation for the ruling, the ethanol industry has been working with CARB to document ethanol as a proven low carbon fuel. Today, the Brazilian Sugarcane Industry Association (UNICA) sent out a statement declaring that sugarcane ethanol’s carbon intensity is even lower than currently calculated by CARB.

“Sugarcane ethanol has a verifiable reduction in greenhouse gases of 90% compared to gasoline. Sugarcane ethanol will easily meet the LCFS, not just in 2020 but today,” said Marcos Jank, UNICA’s President & CEO. UNICA sent out a public statement following the submission of a 25-page letter to the California regulator.

Within this standard, gasoline will be eligible as a “low carbon fuel” if it reduces its current carbon output from 95 grams of carbon dioxide per megajoule (gCO2/MJ) to 86 gCO2/MJ by 2020. Since all biofuels have a lower carbon intensity, they will be a large factor in the reduction of fuel-based carbon.

However, CARB is still considering incorporating indirect land use calculations into the carbon intensity number assigned toeach type of biofuel. According to UNICA, their letter also addresses the controversial calculations resulting from so-called indirect land use change impacts from sugarcane expansion. Their letter supports numerous comments from stakeholders and mentions specifically a letter by 111 PhD scientists stating that the science used to determine such impacts is quite limited, highly uncertain and open to misuse through selective enforcement of such impacts. UNICA’s letter urges CARB to revisit the methodologies utilized in land use change modeling.

Although UNICA’s letter is specific to sugarcane ethanol produced in Brazil, the American ethanol industry has also submitted documentation about the uncertainty of indirect land use and repeatedly called for more research before finalizing the LCFS.