(January 12, 2010) Washington – It’s déjà vu all over again. The state of California is once again attempting to move forward with carbon regulations that would unfairly penalize biofuels while giving other sources of energy a relative free pass.

The California Air Resources Board (CARB) has recently completed a Preliminary Draft Regulation (PDR) for a California Cap-and-Trade Program. In written comments submitted to CARB on Monday, the Renewable Fuels Association (RFA) raised several concerns about the inclusion of liquid biofuels under the cap and the regulation’s treatment of biomass.

“In general, we are greatly concerned by the decision to include liquid biofuels under the cap, given that the carbon neutrality of biomass and biofuels is universally accepted and recognized in carbon accounting practices,” wrote RFA President Bob Dinneen. Biofuels are by definition carbon neutral, noted Dinneen, as the carbon released during their combustion is absorbed by the plants used to make the fuel the following growing season.

CARB agrees that stationary source emissions from the combustion of biomass would be carbon neutral, as described above. However, CARB is curiously not applying the same carbon neutrality to mobile sources of emissions from biomass combustion, i.e. the use of biofuels as liquid motor fuel.

“It appears that the same carbon neutrality assumption is not being consistently applied to…liquid biofuels used for transportation,” wrote Dinneen. “If biomass used for stationary combustion is treated as carbon neutral, all biomass used for all combustion should be treated as carbon neutral under the program.”

Equally troubling is CARB’s continued insistence on assigning carbon penalties to liquid biofuels for both direct and speculative indirect emissions, while only counting direct emissions for traditional energy sources, such as electricity and gasoline. Once again, this creates an unbalanced platform for calculating emissions. All sources of transportation fuel should be analyzed using symmetrical boundaries and uniform metrics.

The complete letter sent by RFA to CARB can be seen here.