In comments submitted to the California Air Resources Board, the Renewable Fuels Association continues to raise concerns regarding the indirect land use change analysis used for the state's Low Carbon Fuels Standard. The comments were submitted in response to the release of final reports from the LCFS Expert Workgroup that was assembled to assist ARB in improving its ILUC analysis.
RFA Vice President of Research Geoff Cooper says that while they continue to have concerns with the selective application of indirect greenhouse gas emissions penalties only to crop-based biofuels in the LCFS, RFA strongly agrees with ARB's decision to adopt a new and improved modeling framework from Purdue. Geoff says the results of Purdue's recent analysis reduce the ILUC penalty for corn ethanol from ARB's current value of 30 grams/megajoule to approximately 14 g/MJ.
However, Cooper cautioned that while the new Purdue model is a major improvement over the version used by ARB for the LCFS, they believe a number of key enhancements are still needed before the model can be reasonably used for regulatory purposes. Overall, RFA believes the workgroup process was useful and advanced the understanding of the challenges associated with modeling ILUC.
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