| First Name: | Patricia |
|---|---|
| Last Name: | Monahan |
| Email Address: | pmonahan@ucsusa.org |
| Affiliation | Union of Concerned Scientists |
| Subject | Carbon accounting using scientific principles |
| Comment |
Attached are UCS's comments on the October LCFS draft regulation, specifically on the question of how to appropriately account for carbon emissions over time. We recommend that CARB consider utilizing scientific rather than economic principles to account for carbon. Bottom line: accounting for the fact that carbon continues to reside in the atmosphere and has a radiative forcing effect for decades worsens the case for corn ethanol and for any biofuel with indirect land use effects. |
| Attachment |
www.arb.ca.gov/lists/lcfs-general-ws/21-ucs_comments_nov_2008.pdf Original File Name: UCS comments_Nov 2008.pdf
Date and Time Comment Was Submitted: 2008-11-14 17:18:05 |
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