California’s efforts to reduce the carbon intensity of the state’s transportation fuels are admirable, but the state’s goals, as outlined in the proposed Low Carbon Fuels Standard (LCFS), are unlikely to be achieved because of the policy’s inherent bias against low-carbon biofuels, says the Renewable Fuels Association (RFA).
In written comments to the California Air Resources Board (CARB) in advance of its April 23 hearing, the RFA outlined concerns about the LCFS that are particularly troubling to conventional and next generation ethanol producers.
Among RFA’s concerns are insufficient land use change analysis. According to RFA, the model CARB relies upon, known as GTAP, is not a mature model for estimating land use change because it does not sufficiently account for increased crop yields in the U.S. as a result of new technologies and includes insufficient feed co-product land use credits. RFA charges that the model also results in an overestimation of forest land being converted.