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UNICA’s Preliminary Comments on Revised Indirect Land Use Change Values Author(s): The Brazilian Sugarcane Industry Association (“UNICA”) appreciates the opportunity to provide comments on the California Air Resources Board’s (CARB) Low Carbon Fuel Standard’s (LCFS) revised indirect land use change (iLUC) values, which were first presented at a workshop on March 11, 2014. Publication Date: 26/04/2014