From: CleanFuelsAug2012

Sent: Wed Sep 05 10:17:21 2012

To: 'Doug Heiken'

Cc: CleanFuelsAug2012

Subject: RE: Clean Fuels Rulemaking - comments

Importance: Normal

Your comments have been received for the proposed Oregon Clean Fuels Program rulemaking. Thank you for your interest.

Cory-Ann Wind

Air Quality Planner

wind.cory@deq.state.or.us

503-229-5388

From: dh.oregonwild@gmail.com [mailto:dh.oregonwild@gmail.com] On Behalf Of Doug Heiken

Sent: Thursday, August 30, 2012 7:42 PM

To: CleanFuelsAug2012

Subject: Clean Fuels Rulemaking - comments

Dear EQC/DEQ:

Please accept the following brief comments from Oregon Wild regarding Phase I of the Clean Fuels Rules. Oregon Wild represents thousands of members and supporters who support our mission to protect and restore Oregon's wildlands, wildlife, and waters as an enduring legacy. Climate change is a significant threat to our mission and we support efforts to reduce (and reverse) greenhouse gas (GHG) emissions to curtail climate change and protect Oregon's environmental treasures.

We support the goal of the clean fuels program to "reduce the greenhouse gases emitted by transportation fuels" as well as secondary benefits such as energy independence and export substitution.

Our main comment is to urge EQC/DEQ to recognize that different fuels have different sources and different impacts, including the variety of fuels that may be called "clean fuels." Some clean fuels are much more beneficial than others in meeting the goal of GHG emissions reductions.

Clean fuels derived from highly subsidized and energy intensive corn other grains are of particular concern. There is mounting evidence that fuels derived from corn do not contribute to emissions reductions goals. Corn's dependence on nitrogen fertilizers erases many of the benefits.

During the reporting phase of these rules, it is important to distinguish between different fuels and different sources of fuels so that the contribution to GHG emissions reduction objectives can be clearly assessed. The rules should require clear reporting of the source of fuels as well as information related to production of different fuels:

• * net energy return,
• * land use change,
• * agricultural/silvicultural practices and inputs,
• * industrial inputs and processes,
• * transportation inputs and costs,
• * air and water impacts,
• * food supply impacts

These factors are all highly relevant to the question of whether clean fuels are really in the public interest.

Sincerely,

/s/

_____________________________________

Doug Heiken, Oregon Wild

PO Box 11648, Eugene OR 97440

dh@oregonwild.org, 541.344.0675