Earth Day 2009 is ironically the final day for filing written comments with the California Air Resources Board (CARB) on a proposed low-carbon fuel standard, or LCFS, that threatens to undermine the role of renewable fuels in helping the environment.

An increasing number of university professors, scientists, researchers, and industry trade organizations have registered their opposition to the controversial proposal because they say incomplete and unproven modeling is being used to penalize renewable fuels.

Among the flaws in the proposal pointed out by the National Corn Growers Association (NCGA) in formal comments submitted to CARB this week is that it ignores the great growth in corn production per acre, or yield, that is expected to take place in the coming decade.

“Using yield data updated only through last year, the proposal’s analysis through 2015 assumes no growth in yield,” NCGA President Bob Dickey said. “This is like assuming we will all use the same computer and same technology in 2015 that we’re now using.” With the use of new technologies which allow desirable traits and genes to be identified and deployed much more quickly, annual yield increases may average 2.5 percent or greater into the future.

“America’s corn growers are eager to play a central role in the decarbonization of transportation fuel,” Dickey concluded in the written comments. “However, if adopted as currently proposed, the standard will uniformly dissuade the production and use of all forms of biofuels that utilize land and undercut what is a tremendous opportunity to spur economic growth in agricultural communities and reduce carbon emissions with American farming.”

Written comments may still be submitted until noon pacific time today by going to the CARB website. The formal public hearing will be Thursday and Friday of this week after which a vote will be held and a ruling made.