By Ann Bailey, Ethanol Producer Magazine.
The Renewable Fuel Association has written the Oregon Department of Environmental Quality a letter expressing displeasure with the state’s proposed amendments for its Oregon Clean Fuels Program.
The association has been an enthusiastic supporter of carbon fuel programs using fair, consistent and scientifically robust methods to evaluate, for all fuels, the lifecycle carbon intensity (CI), said the Oct. 21 letter written by Geoff Cooper, senior vice president of RFA. The RFA was surprised and disappointed, then, to learn that the recently proposed rule includes the addition of what the organization sees are subjective penalty factors for “hypothetical indirect and use charges (ILUC), for select biofuels, but no direct penalty for any other fuel types,” the letter said.
“Moreover, the ILUC factors, DEQ is proposing to incorporate are entirely arbitrary and have nothing to do whatsoever with the expected actual carbon impacts of CFP implementation in Oregon for the 2015-2016 timeframe,’’ Cooper wrote.