On 23 April 2009, the California Air Resources Board approved the specific rules and carbon intensity reference values for the California Low-Carbon Fuel Standard (LCFS) that will go into effect on 1 January 2011 [REF].
A similar controversy arose after the U.S. Environmental Protection Agency (EPA) published on 5 May 2009, its notice of proposed rulemaking for the new Renewable Fuel Standard (RFS) [REF].