Testimony to California ARB on Proposed Re-Adoption of LCFS

The Clean Air Task Force supports the re-adoption of California's Low Carbon Fuel Standard (LCFS) through 2020 but opposes reducing the carbon intensity value for corn ethanol. The organization argues that the current modeling used to justify a lower indirect land use change (ILUC) score is based on subjective decisions, specifically the assumption that biofuel expansion leads to a reduction in food consumption that provides a climate benefit. CATF contends that if food consumption declines were limited, corn ethanol's ILUC emissions would increase substantially, and that relying on corn ethanol would hinder the development of more effective compliance options.

• The Clean Air Task Force supports the re-adoption of the Low Carbon Fuel Standard (LCFS) through 2020, describing it as the "most promising policy tool available for reducing the climate impacts of the transportation sector."
• The process of determining indirect land use change (ILUC) scores for corn ethanol is characterized as a "subjective process" involving choices about which datasets to use and how to program relational assumptions in lifecycle models.
• The current ILUC estimates used by the California Air Resources Board (ARB) depend on the subjective decision to count greenhouse gas reductions resulting from reduced food consumption as a climate benefit.
• If the ARB assumed that society would limit the decline in food consumption, the estimated ILUC emissions for corn ethanol would increase substantially.
• Reducing the carbon intensity value for corn ethanol is viewed as undermining LCFS objectives because it relies on assumptions about reduced food consumption in developing countries and may discourage the development of more innovative compliance options.

APA

Lewis, J. (2015). Testimony to California ARB on Proposed Re-Adoption of LCFS. Clean Air Task Force. https://cdn.catf.us/wp-content/uploads/2019/10/21093337/20150219-LCFS-ReAdoption_Oral_Final.pdf

Chicago

Lewis, Jonathan. Testimony to California ARB on Proposed Re-Adoption of LCFS. Clean Air Task Force, 2015. https://cdn.catf.us/wp-content/uploads/2019/10/21093337/20150219-LCFS-ReAdoption_Oral_Final.pdf.

Wikipedia

{{cite press release |last1=Lewis |first1=Jonathan |title=Testimony to California ARB on Proposed Re-Adoption of LCFS |publisher=Clean Air Task Force |date=19 February 2015 |url=https://cdn.catf.us/wp-content/uploads/2019/10/21093337/20150219-LCFS-ReAdoption_Oral_Final.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{lewis2015testimony, author = {Lewis, Jonathan}, title = {{Testimony to California ARB on Proposed Re-Adoption of LCFS}}, publisher = {Clean Air Task Force}, year = {2015}, month = feb, url = {https://cdn.catf.us/wp-content/uploads/2019/10/21093337/20150219-LCFS-ReAdoption_Oral_Final.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }