UNICA comments on California’s proposed Low Carbon Fuel Standard (LCFS) |
Apr 2009
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The Brazilian Sugarcane Industry Association (UNICA) is the leading trade association for the sugarcane industry in Brazil, representing nearly two thirds of all sugarcane production and processing in the country. Their 125 member companies are the top producers of sugar, ethanol, renewable electricity and other sugarcane co-products in Brazil’s South‐Central region, the heart of the sugarcane industry. Brazil is the world’s largest sugarcane‐producing country with over half a billion metric tons of cane harvested yearly.
This document/letter provide UNICA’s specific comments on California’s proposed Low Carbon Fuel Standard (LCFS). It includes issues regarding lifecycle calculations of sugarcane ethanol and includes a number of specific recommendations concerning the calculations of indirect land use change.
The letter is structured as follows:
Introduction of UNICA as having a direct and significant interest in this rulemaking;
Comments and recommended changes to life cycle assessment inputs and assumptions;
Comments and recommended changes to land use change calculations; and,
Conclusions.
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