Comment Log Display

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.