Comment Log Display
Below is the comment you selected to display.
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.
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2011-04-28 14:37:14
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.