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CARB's  plans for assigning carbon intensity to biofuels greatly
underestimate the real "carbon intensity" (climate warming effect
of specific fuel uses) for all crop-sourced biofuels.  The
phenomenon of particular importance here, called ILUC for "indirect
land use change",  has been known and studied at least since 2008;
I was the principal investigator of CARB contract research at the
University of California when ILUC was incorporated into LCFS
estimates.  In simplest form, by processes well-known to CARB
staff, withdrawing goods  from world commodity markets (for
example, soybean oil in the US) sets in motion price changes that
induce increased production of similar or substitutable goods (for
example, palm oil in Indonesia) elsewhere, on land whose conversion
to crops (usually from forest or cerrado) releases very large
greenhouse gas (GHG) discharges directly attributable to the
food-to-biofuel diversion.  
The GTAP economic model used by CARB to estimate indirect land use
change is seriously and systematically flawed in ways detailed in
the "Report on the Economic Basis for GTAP and Use of GTAP Style
Models in Biofuel Land Use Modeling"  by Steven Berry, Timothy
Searchinger, and Anton Yang, from the Yale Tobin Center for
Economic Policy. This report has been separately submitted to CARB
by its authors.  The effect of continuing to use GTAP to estimate
biofuel carbon intensity undermines the intent of the LCFS and will
displace real GHG reduction with increased fuel use that actually
increases global warming, in addition to causing extremely damaging
biodiversity loss and cultural injury, especially in tropical
forests. 
CARB would better serve the climate policy goals of the LCFS by
scoring the actual carbon intensity of biofuels than using GTAP to
estimate land use change effects.  I urge CARB to attend carefully
to Berry et al's critique and amend the LCFS carbon intensity
scoring system accordingly.