Comments to the California Air Resources Board by the Clean Air Task Force On the Proposed Re-Adoption of the Low Carbon Fuel Standard

The Clean Air Task Force (CATF) supports the readoption of California's Low Carbon Fuel Standard (LCFS) through 2020 but argues against reducing the indirect land use change (ILUC) emissions score for corn ethanol. CATF contends that current modeling, specifically the CA GTAP-BIO model, underestimates emissions by ignoring water scarcity, failing to differentiate between commercial and non-commercial forests, and using flawed yield price elasticity assumptions. The document also highlights the negative impact of corn ethanol on global food security and proposes liquid ammonia as a scalable, low-carbon fuel alternative for the post-2020 period.

• CATF supports the readoption of the LCFS through 2020, describing it as the "most promising policy tool available for reducing the climate impacts of the transportation sector."
• CATF opposes the proposed reduction of the indirect land use change (ILUC) score for corn ethanol from 30 gCO2/MJ, arguing that such a change would reward corn for its "negative impact on global food security" and undermine the program's innovation goals.
• The CA GTAP-BIO model used by ARB is criticized for underestimating ILUC emissions because it does not account for water scarcity constraints. Research cited by CATF suggests that ignoring irrigation constraints can lead to underestimating induced land use emissions by "more than one quarter."
• CATF identifies several technical flaws in the GTAP model's emissions accounting, including its inability to distinguish between commercial and non-commercial forests and the use of a single yield price elasticity (YPEL) value that fails to capture variability across different crops and regions.
• The document argues that ARB's lifecycle analysis is subjective because it counts GHG reductions resulting from reduced food consumption as a climate benefit; if food consumption were held constant, ILUC emissions for corn ethanol would increase by more than 5 gCO2/MJ.
• CATF proposes liquid ammonia as a highly scalable, affordable, zero-carbon fuel alternative for the post-2020 period, noting that it can be produced using renewable or nuclear power and utilizes existing global transport infrastructure.
• A demonstration project in Los Angeles involving UCLA, the California Energy Commission, and the South Coast Air Quality Management District (SCAQMD) is testing a multifuel (gas and ammonia) combined-heat-and-power system at California Metal-X (CMX) to provide low-cost, clean electricity.

APA

Clean Air Task Force (2015). Comments to the California Air Resources Board by the Clean Air Task Force On the Proposed Re-Adoption of the Low Carbon Fuel Standard. https://cdn.catf.us/wp-content/uploads/2017/10/21093227/20150219-CATF-Comments-to-ARB-on-LCFS-Re-Adoption_wApp.pdf

Chicago

Clean Air Task Force. Comments to the California Air Resources Board by the Clean Air Task Force On the Proposed Re-Adoption of the Low Carbon Fuel Standard. 2015. https://cdn.catf.us/wp-content/uploads/2017/10/21093227/20150219-CATF-Comments-to-ARB-on-LCFS-Re-Adoption_wApp.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Comments to the California Air Resources Board by the Clean Air Task Force On the Proposed Re-Adoption of the Low Carbon Fuel Standard |date=19 February 2015 |url=https://cdn.catf.us/wp-content/uploads/2017/10/21093227/20150219-CATF-Comments-to-ARB-on-LCFS-Re-Adoption_wApp.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2015comments, author = {{Clean Air Task Force}}, title = {{Comments to the California Air Resources Board by the Clean Air Task Force On the Proposed Re-Adoption of the Low Carbon Fuel Standard}}, publisher = {Clean Air Task Force}, year = {2015}, month = feb, url = {https://cdn.catf.us/wp-content/uploads/2017/10/21093227/20150219-CATF-Comments-to-ARB-on-LCFS-Re-Adoption_wApp.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }