Californian Air Resource Board (CARB)
“ARB staff has concluded that the land use impacts of crop-based biofuels are significant and must be included in LCFS [California Low Carbon Fuel Standard] fuel carbon intensities. To exclude them would allow fuels with carbon intensities that are similar to gasoline and diesel fuel to function as low-carbon fuels under the LCFS. This would delay the development of truly low-carbon fuels and jeopardize the achievement of a 10 percent reduction in fuel carbon intensity by 2020.”
CARB (2009): Proposed Regulation to Implement the Low Carbon Fuel Standard. Volume I.
http://www.arb.ca.gov/fuels/lcfs/030409lcfs_isor_vol1.pdf
US Environmental Protection Agency (EPA)
“…it would be far less scientifically credible to ignore the effects of land use changes altogether than it is to use the best approach available to assess these known emissions sources.”
“We believe that uncertainty in the effects and extent of land use changes is not a reason for not accounting for land use change emissions.”
EPA (2009): Draft Regulatory Impact Analysis: Changes to Renewable Fuels Standard Program.
http://www.epa.gov/orcdizux/renewablefuels/420d09001.pdf