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Comment 4 for Comments for the LCFS Method 2A2B applications (lcfs2a2bcomments-ws) - 2nd Workshop.


First Name: marcia
Last Name: fonte
Email Address: marciafonte@comcast.net
Affiliation:

Subject: New Molasses Pathway to Raizen Costa Pinto of 14.93 gCO2e/MJ
Comment:
CARBís LCFS program has been a terrific instrument for promoting
the development of new state of the art technologies to produce
lower carbon fuels. We have seen tremendous investment on
breakthrough technologies not only for the production of the
biofuel itself but also, and by no means less important, on the
agricultural practices and technologies. The benefits of these
advanced methods of making fuels have had an immense impact on the
environment and overall economies around the world, creating jobs
and making the world a cleaner and safer place to live. That being
said, we were very surprised to learn late in December that CARB
was now recommending the approval of a new pathway for a really low
CI of 14.93 gCO2e/MJ to an old sugar mill that have invested little
to none in improving their carbon footprint throughout the years.
 
We would like to kindly ask CARB whether it is saying that it is
best for an investor interested in supplying low carbon fuels to
the California market to acquire a 4 decades old sugar mill in
South America than it is to invest on the development of
breakthrough technology? Cellulosic, for instance? Is CARB also
saying with this recommendation that the production of ethanol from
Brazilís older sugar mills that have been producing ethanol from
molasses since the start of the ethanol program in the 70ís better
for the environment than the new state of the art, also sugarcane
based, ethanol only facilities, fully mechanized and co-generating
in the same region? Well, not only better, but arguably 4 times
better considering a CI 58.4 vs. the 14.98 being recommended?
 
The truth is the molasses in Brazil has not been a by-product of
sugar for decades as it still may be the case in other parts of the
world. Brazilian sugar mills like Costa Pinto that requested this
specific pathway have been making ethanol for decades alongside
with sugar, adjusting their percentages according to the market
incentives of the moment. Moreover this statement is true for a
vast majority of mills in Brazil, in particular the older sugar
mills in the state of S„o Paulo, that would become the preferred
choice of ethanol for California if CARB approves this pathway.
Letís not kid ourselves, the carbon to produce the ethanol from
this molasses is there just like it is with other sugar cane mills,
so basically we would just be saying that the sugar takes all the
blame for the CO2 emissions and the ethanol does not.
 
In sum, we believe the basis for this pathway is certainly not in
line with the intent and fundamentals of the LCFS program and it
should not be approved by CARB. This pathway approval would be
giving the wrong message to the entire industry that would
otherwise be investing in newer and better technologies to make
this world cleaner and our environment safer. We salute CARB for
being the steward of just a great program maintaining its core
values and goals despite all the political pressures. We trust
youíll be making the proper judgement on this case.

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Date and Time Comment Was Submitted: 2014-01-08 07:34:42



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