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Comment 3 for LCFS Program Review Advisory Panel (2011) (lcfsadvisorypanel-ws) - 2nd Workshop.


First Name: Robert
Last Name: Freerks
Email Address: rfreerks@Rentk.com
Affiliation: Rentech, Inc

Subject: Establishment of CI Categories for Fuels
Comment:
Under Topic 5, Ultralow Carbon Fuels, it is being proposed that a
category of fuels with CI less than 40% of conventional fuels (a
60% reduction in CI) be established.  This would match a similar
category of fuels as defined by the RFS2  regulations.  However, a
60% reduction in CI for biofuels is not the ultimate goal for
biofuels and setting this threshold as the ultimate goal may
actually be counterproductive.  Rentech and other biomass to liquid
fuels producers can obtain much lower carbon intensity in the
production of drop-in hydrocarbon fuels than others by using
gasification/F-T/hydroprocessing technology.  In addition,
Cellulosic Ethanol producers can also achieve very low CI values if
they capture and store CO2 from their process as well.

BTL fuels such as those proposed by Rentech are 100% drop in fuels
with extremely low CI.  This CI is obtained by very efficient
utilization of biomass resources and by co-production of
electricity.  Rentech has conducted several life cycle assessments
in conjunction with Life Cycle Associates and determined that fuels
can be produced with negative CI in most cases, and with CI of less
than 10 gCO2e/MJ from all resources we have looked at.  Rentech has
made it a corporate policy to use only resources that are not
competing with food and do not have indirect land use change issues
such as seen with other energy crops such as corn and soybeans. 
Using forest waste and mill waste feedstocks, Rentech has achieved
CI’s of  -6 to -18 gCO2e/MJ for forest waste to liquids projects.  
This range is dependent on the mix of mill waste (-18) or forest
products (-6), but in all cases the CI is negative.  

For a project that using urban green waste, the CI is approximately
-50 gCO2e/MJ with credit for co-production of a significant amount
of green power onsite.  

We are concerned that if the ARB is going to set categories for the
CI of fuels and not credit for the specific CI of that fuel.  We
suggest that they consider including more categories than just the
60% reduction from conventional fuels as RFS2 does.  Additional
categories such as 80%, 100%, 120% and beyond should be considered
if this approach is used.

If California is going to reach a true CI reduction for fuels
beyond the 10% currently proposed, it is going to need fuels with
CI values as low as possible.  Rentech has already established that
very low CI fuels are capable of being produced, and we have not
yet incorporated all potential engineering processes for further
reducing the CI of fuels.  A simple example is to utilize carbon
capture in the process which is already being done during synthesis
gas cleanup.  If the CO2 captured during production of syngas and
during F-T synthesis is captured, a further 30-50% reduction in CI
is achievable using currently available technology.  We should not
be discourages from pursuing this technology due to the simple
issue of setting a target CI based on the RFS2 legislation.

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Date and Time Comment Was Submitted: 2011-04-28 14:37:14



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