Comments on the California Air Resources Board Draft Proposal for the California Low Carbon Fuel Standard Regulation

November 12, 2008

NRDC strongly supports many aspects of the draft proposal, particularly, the establishment of separate standards for gasoline and diesel fuels; the intention to establish separate emission factors for fuels derived from non-conventional crude oil sources, especially tar sands; and the inclusion of the indirect land use change (ILUC) GHG emissions in the alternative fuel carbon intensity emission factors for biofuels, to name a few.

However, we believe the current proposal falls short in a number of ways, and we therefore have recommendations such as providing minimum lands safeguards for biofuel protections that are consistent with analogous federal protections to ensure there is not an unintentional inventive to make biofuels using materials from ecologically sensitive areas that could actually increase GHG emissions.