First Name: | Jeannie |
---|---|
Last Name: | Blakeslee |
Email Address: | jblakesl@arb.ca.gov |
Affiliation | CAPCOA |
Subject | LCFS Multimedia Evaluation Functional Equivalent (submitted via internal email) |
Comment |
Low Carbon Fuel Standard CAPCOA supports the goal of the Low Carbon Fuel Standard adopted by ARB to reduce the carbon intensity of transportation fuels. However, to ensure that local and regional air quality impacts are not exacerbated in the process and that energy reduction goals are actually realized, extensive analysis will be required prior to development of the implementing regulation, including the following: 1. Evaluation of the toxic and criteria pollutant impacts of biofuels to ensure that public health is not compromised in implementing this measure. 2. Analysis of the impact of biofuels on broader societal issues and how these might affect implementation effectiveness, such as the potential for the regulation to create “domino” effects on grains and crops that ultimately affect food availability and cost. 3. Development of better tools to assess and audit land use implications of the various strategies, such as potential conversion of pastures, rainforests and other existing carbon sinks to fuel production and how that will affect the global carbon balance. 4. Analysis of the potential to increase light-duty vehicle dieselization if a market-based, averaging mechanism for fuel carbon content is used to provide regulatory flexibility. |
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Original File Name:
Date and Time Comment Was Submitted: 2008-12-10 13:56:41 |
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