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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: firstname.lastname@example.org
Subject: New Molasses Pathway to Raizen Costa Pinto of 14.93 gCO2e/MJ
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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