The carbon emissions category is called indirect or market-mediate effects.

In a letter to California Governor Arnold Schwarzenegger, they acknowledged that all fuels have indirect carbon effects. But they challenged the notion that they are well understood and were critical of the plan to enforce indirect carbon effects on biofuels only.

The letter recommends that California adopt LCFS regulation based on direct carbon effects, or those emissions directly attributable to the production and use of the particular fuel.

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