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Comment 7 for Comments for the LCFS Method 2A2B applications (lcfs2a2bcomments-ws) - 2nd Workshop.
First Name: Carla
Last Name: Pires
Email Address: firstname.lastname@example.org
Affiliation: Council of Sustainability of FDC
Subject: Molasses Pathway - About the criteria and LUC
Dear Sirs, We think that to take the assumption of the GHG emissions for the ethanol productions, like demonstrated on the worksheet “EtOH Prod”, transportation, distribution and other phases is reasonable to take in consideration all the process related to the calculation of the emissions for the pathway. The presented pathway that is been recommended by CARB, took into consideration information as determined in Detailed California-Modified GREET Pathways for Brazilian Sugarcane Ethanol: Average Brazilian Ethanol, version 2.3, September 23, 2009 and particular data from the mill, considering all the time the allocation factor of 0,34 (by TRS). But we have the follow questions: - The “allocation” made for the considered LUC is not in the same way (and based on the same reasoning) of the other allocations in the pathway. The CARB 2009 value of 46 g CO2e / MJ ethanol was calculated dividing the (final total LUC emissions related to a cane area) by the (MJ in ethanol produced from all the cane juice in this area). So, if we produce only 34% of this ethanol, and assign to it a cane area also 34% of the total (by TRS allocation), we would have the same 46 g CO2e / MJ produced ethanol from molasses, other variables kept constant. So, we can´t use the factor of 34% in LUC calculation for molasses, when the result of 46 g CO2e / MJ ethanol is specifically calculated for the ethanol. - It is not clear the calculation method for the electricity cogeneration and export credit. So, we would like to have more information. In addition to that, we would like to EMPHASIZE that the emissions of LUC for ethanol from sugarcane juice must urgently be reviewed, otherwise will be created a difference of 30.21 g CO2e / MJ ethanol between the molasses based ethanol and the ethanol from sugarcane juice. The impact of this difference isn’t correct and consequently, also, isn’t fair. We hope to have some answers before the approving of this pathway.
Original File Name:
Date and Time Comment Was Submitted: 2014-01-08 11:43:50
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