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Comment 16 for Comments for the LCFS Method 2A2B applications (lcfs2a2bcomments-ws) - 3rd Workshop.

First Name: Sydney
Last Name: Bacchus
Email Address:

Subject: Public Comments for Application 71 for pathways for the Low Carbon Fuel Standard (LCFS)
My comments are provided as "Public Comments" for application 71
for pathways for the Low Carbon Fuel Standard (LCFS), from the
following link:

My comments identify actual or methodological errors in Western
Plains Energy's renewable diesel (RD) produced by growing corn and
sorghum in Kansas to convert to ethanol.

Application 71:
Application 71 is by Western Plains Energy to grow corn and sorghum
in Kansas to convert to ethanol.

Both are agricultural crops that divert farmland critical from
growing food for Americans at a time when the US position is that
current food production is inadequate to meet future needs.

Corn is one of the most irrigated crops grown in the US.
It is common knowledge that US aquifers and surface waters,
particularly those used for industrial agriculture, have been
depleted to the point where future agricultural production for food
is in jeopardy.

Corn also is one of the most heavily fertilized crops grown in the
A prime ingredient of the fertilizer used for most of the
agricultural crops in the US is phosphate rock that is mined in
This mining process is highly energy intensive, consuming massive
quantities of petroleum-based diesel fuel and producing deadly
concentrations of particulates from a combination of the diesel
fuel and mining dust that leaves surrounding rural areas resembling
the dust-bowl era of decades past.

Phosphate mining also requires hundreds of millions of gallons of
water per day for the processing of the mined rock.
Additional the mining process leaves huge gaping mine pits,
hundreds of acres in size, in the surficial aquifer that results in
continual dewatering of the regional aquifer system via evaporation
from the mine pits.

Please refer to the comments of rural residents subjected to the
clouds of particulate air pollution and dewatering of their
property from this mining (e.g., Norma Killebrew) and my comments
in the US Army Corps of Engineers' Areawide Environmental Impact
Statement (EIS) for continued phosphate mining in central Florida
for more details on the air quality contamination and irreversible
dewatering of the aquifer system that results from the mining to
produce fertilizer for crops such as the corn and sorghum proposed
for ethanol in this application.

This application did NOT include or address these air quality or
irreversible water resource depletions for fertilizing, irrigating
or fueling farm equipment to produce the corn or sorghum.
Therefore, this source of fuel canNOT be considered renewable or a
source that would reduce air quality contaminants.

Application 71 should be denied.
Sydney Bacchus, Ph.D.


Original File Name:

Date and Time Comment Was Submitted: 2014-01-31 19:47:35

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