First Name: | Charles |
---|---|
Last Name: | Alexander |
Email Address: | sushibar@excite.com |
Affiliation | |
Subject | In re, (inter alia) Ultra-low carbon fuel (hydro-electric dam generated electricity) |
Comment |
Thank you for the opportunity, herenow, to provide Comment on "Low Carbon Fuel Standard 2011 Program Review Report." Now, at various places in the "Low Carbon Fuel Standard 2011 Program Review Report; Working Draft, Version 1" (herein after referred to as "the Report") optimism is expressed that, as standards become progressively more stringent, that the fact of it will spur investment in research into and development, production, distribution, & (ultimately) retail sales of ultra-low carbon fuels. Recent events up in Siskiyou County, among other things, should temper some of that optimism. For instance, there are those endeavoring to remove several hyrdo-electric dams in Siskiyou County, and another in eastern Shasta County. Additionally, these same entities have been endeavoring to abrogate (or at least derogate) the water rights of farmers & ranchers living in Siskiyou County. If these entities ultimately succeed, they will remove from the electricity grid in California a number of different ULTRA-LOW CARBON sources of electricity. Additionally, dam removal will remove water availability from senior water rights holders, including many lesser-capitalised farmers & ranchers. Operation, permitation, maintenance, etc. of the pumps, etc. that would replace all those dams (for the water rights holders) would be significantly more expensive than the use dam water. This is expected to cause at least some lesser-capitalised water rights holders to remove their lands from availability for to cultivate crops. This, in turn, will cause inflationary pressures brought to bear upon food prices (already) by biofuel production & mandate to be even WORSE. And this in addition to the fact that the cultivation of biofuel feedstock requires land. And when land is removed from crop-availability, this brings inflationary pressures to bear BOTH on the price of food & on the price of biofuel feedstock. Pumps require fuel. When dams are removed, the carbon index (CI) of electricity in California will inevitably increase! It's a simple matter of mathematics. Compliance with LCFS targets will be more difficult! Already, carbon net deficits are expected to be generated by approximately 2017. Removal of hydro-dams & of irrigation dams will make that problem even worse. Under Executive Order S-06-06, by 2020, 40% of all biofuels used in California will have to be produced in California (see pg. 30 of Report, inter alia). How is that to happen when hydro-dams & irrigation dams are proposed to be removed? Incidentally, when a dam is removed, all the sediment that settles at the base of it is released downstream, killing many fish (especially those endangered). And some of that sediment can be expected to deposit in downstream spawning beds, thus exacting long-term toll on fish populations. Is this at all in keeping with the ideas of Sustainability? No. It is not! On pg.s 59 & 60 of the Report, it was noted that, during a 6 yr. survey period between 2004 & 2010, increased crop-based biofuel production has contributed significantly to increases in extreme poverty, particularly in South Asia & in Sub-Saharan Africa, not to mention increases in hunger-related diseases & tthus to decreases in life expectancies in those affected populations. And when crop-land in Northern California is taken out of circulation, the problem can get even WORSE, because yet additional inflationary pressures are thus brought to bear upon both food commodity & biofuel feedstock commodity prices. Fuels like "algae-gasoline" & "algae-diesel" are yet many years away from large-scale retail availability. Also, butanol is still not yet available for retail. So what is left is that ultra-low carbon electricity is being proposed to be taken off the market, whilst next generation low-carbon fuels like butanol, "algae-gasoline," & "algae-diesel" are still a number of years yet into the future. First generation biofuels, such as corn-ethanol, whose CI is the same as that for gasoline (BTW), production of which 1st Gen biofuels has imposed inflationary pressures on food-commodity prices, end up in the line-up by default. But is THIS the way to move forward with a LCFS? How is latter-year compliance supposed to be achieved under those conditions? The only answer is that of ultra-low carbon electricity! And that means hydro-dams! They must not be removed! Calculate separately the CI of electricity generated by hydro-dam from that of electricity State-wide & there is no contest. Hydro-dams are an extremely low-carbon way of generating electricity! Hydro-dam generated electricity is an already existing ultra low carbon fuel! Why take it off the market? And if existing crop land is allowed to remain in circulation, inflationary pressures that would have (by the crop-lands being taken out of circulation) been brought to bear upon both food-commodity & biofuel feedstock commodity prices are thus NOT added to the inflationary pressures that biofuels already bring to bear upon food-commodity prices. But one thing, inter alia, is essential. The dams must NOT be removed!! It would behoove ARB, & anyone reading this, to contact all relevant State & Federal agencies & urge them to save the hydro-dams. Thank you. P.S., On a positive note, it is good that, in several places in the Report, there is mention of inclusion of indirect land use effects in calculation of CI values. This must remain an indelibile part of the LCFS! Thank you. |
Attachment |
Original File Name:
Date and Time Comment Was Submitted: 2011-11-16 20:39:56 |
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