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UNICA’s Comments on the Updated Indirect Land Use Change Analysis of the Low Carbon Fuel Standard 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) update on indirect land use change (ILUC) analysis. UNICA’s comments are based on the information provided during the September 29th ILUC workshop as well as on the simulations of the Global Trade Analysis Project (GTAP) model, available online at Purdue University’s website. Publication Date: 26/10/2014