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Comment 4 for LCFS Program Review Advisory Panel (2011) (lcfsadvisorypanel-ws) - 3rd Workshop.


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

Subject: Comments on NRDC Presentation to Advisory Panel 1 July 2011
Comment:
Rentech Comments on Presentations to CARB LCFS Advisory Board
Presentations
At the California Air Resources Board LCFS Advisory Panel Meeting
held on 1 July 2011 in Sacramento, NRDC and Wood-McKenzie presented
views on the impacts of CARB rulings on the use of High Carbon
Intensity Crude Oil in California fuel meeting the LCFS.
Rentech, Inc. is developing technology and products to help Federal
and State governments meet Renewable Fuels Standards and Low Carbon
Fuel Standards utilizing a combination of biomass and where
appropriate, fossil resources.  Rentech is committed to producing
fuels with carbon intensity values below that of conventional
fossil based fuels by using advanced engineering technology and
appropriate resources in the most efficient manner.  
An example of this effort is the Rentech Rialto Renewable Energy
Center.  This project is being designed to produce 1200-1500
bbl/day of liquid hydrocarbon fuels that are direct replacements
for conventional fuels and refinery products.  Based on independent
life cycle assessment data provided by Lifecycle Associates, fuels
produced from the Rialto facility will have baseline carbon
intensity of approximately 5% of conventional fuels; and using
reasonable estimates of the alternative fates of the feedstocks
used in this project, the CI of these fuels will be much less than
that.
Rentech is also developing a project in Ontario, Canada where
unmerchantable wood and wood waste would be converted into fuels
and power with a CI for the fuel being below zero, or greater than
100% reduction in CI compared to baseline fossil fuels.
Rentech is also developing technology to produce fuels from fossil
resources utilizing combined fossil and biomass gasification.  The
project located in Natchez, MS is designed from the start to be a
low carbon emissions plant using Carbon Capture and Storage to
reduce the GHG emissions from the production of fuels at that
plant.  CCS technology is 100% integrated into this plant design,
and is in fact a requirement of the design.  Therefore permanent
storage of the captured CO2 is actually a profitable part of the
plant economics and not just a means of disposal of a waste stream.
 Rentech is partnering with Denbury Resources to utilize CO2 from
CTL for EOR which will produced an additional 2 bbl of crude per
bbl of F-T products produced.  This has benefits both for storage
of CO2 and reduction of dependence on imported crude which often
has higher environmental impact than domestic production.
I mention this aspect of the Rentech CBTL plant design in response
to a slide presented by NRDC at the 1 July CARB LCFS Advisory Panel
meeting.  Slide 2 of the NRDC presentation is shown below, Figure
1. In this slide, NRDC shows that Coal to Liquids projects have GHG
emissions of 120% greater than those of conventional fossil based
fuels.  Although this is theoretically approximately correct
(numbers vary from 80% to 130% greater than fossil fuels), it is a
very different picture of the CTL industry as it would exist in the
US.  Based on current regulations and political realities, no CTL
facility in the US would produce fuels with a CI greater than that
of fossil fuels produced in 2005 based on Section 526 of the EISA
of 2007.  There simply would not be a market for fuels produced
from CTL technology without CCS and without meeting the Section 526
requirement.  
Rentech’s advanced design for a CBTL plant produces fuels with a CI
of 70 gCO2e/MJ, substantially below the CARB LCFS baseline for
fossil derived diesel fuel of 94.71 gCO2e/MJ.  The reduction in CI
for CBTL fuels produced by a project such as Rentech’s Natchez
facility can be put into context using CARB LCFS fuel production
pathway data.
 
Figure 1  Slide 2 from NRDC Preseentation to CARB LCFS Advisory
Panel 1 July 2011

Figure 2 shows the CI of several conventional and alternative fuels
as reported in CARB documents.  Note that the CI for fuels from the
Natchez CBTL plant is below that for Hydrogen, Ethanol, Biodiesel,
and Electricity when used in EV’s.  
Based on our analysis and the view that no CBTL plant is being
planned or permitted that would vent CO2 at the rate shown in the
NRDC presentation, we submit that the NRDC value for GHG emissions
from a CTL plant are extremely out of line with reality, or reality
as it exists in North America for CTL plants.  And we further
submit that CBTL plants are much more realistic to build in the
current regulatory environment and that the GHG emissions from
these plants is much more representative of what CI value should be
considered for coal derived fuels.  
As CTL as depicted by NRDC has the highest GHG emissions of any
alternative fuel, and the volume production is 1/3 of the total
shown in NRDC slide 3, we believe that the “Change in Carbon
Intensity v. 2005 Baseline” shown in Slide 4 of the NRDC
presentation is very inaccurate.  

 
Figure 2 Comparison of CI for fossil and alternative fuels per CARB
LCFS vs Rentech Rialto Renewable Energy Center baseline CI.
The ability of a CBTL facility to produce larger volume of fuels
with reduced CI compared to biofuels can be illustrated as
follows:
•	CBTL facility produces 10,000 bbl/day (153,000,000 gal/yr) of
alternative fuel (partially biomass derived)
•	CI of CBTL fuel is 70 gCO2e/MJ
•	Comparison between CBTL and Biodiesel with CI of 88.9 gCO2e/MJ
•	Rentech CBTL plant produces equivalent GHG emissions as
production of 42,530 bbl/day of biodiesel (651,900,000 gal/yr or
over 50% of all biodiesel production)
Thus economies of scale for using biomass with fossil resources
results in net reduction of GHG emissions without competition for
food and land resources, and also water resources needed to make
such fuels as 1st generation biodiesel fuel.
Rentech’s RenDiesel is a drop-in replacement for conventional
diesel fuel, unlike many 1st and 2nd generation biofuels such as
ethanol, biodiesel, and pyrolysis oil derived fuels.  We find it
interesting that NRDC would choose to use KiOR technology as
representative of fuel input switching.  To our knowledge, KiOR has
not presented a LCA study on their process, nor has KiOR presented
data on their fuel product.  Pyrolysis oil is a highly toxic and
corrosive product that will represent risks during transportation
to refineries where it is proposed to be upgraded into finished
fuel.  This upgrading process will consume large quantities of
hydrogen which most likely is produced from fossil fuels (mostly
natural gas).  PNNL estimated that partial upgrading of pyrolysis
oil into liquid fuels consumes 5,000 SCF/bbl of pyrolysis oil
(Ellott & Neuenschwander, PNNL, 1996).  The level of
hydroprocessing only reduced oxygen in the feedstock by 95-98%. 
Complete removal of oxygen is required to meet diesel fuel
specifications.  
PNNL presented data at the Smallwood conference (May 13-15, 2008 in
Madison, WI) showing that H2 consumption for complete upgrading of
pyrolysis oil can consume up to 47,000 SCF/bbl of pyrolysis oil
processed.
Rentech presents data on its process and products openly.  We
welcome open presentation of data from other producers so that all
aspects of fuels production from biomass, fossil, or a combination
of these resources can be discussed, compared and evaluated for
efficiency of biomass utilization and production of useful
commercial fuels for the transportation sector.  Only when all the
data is made available can useful discussions about options for
meeting the LCFS provisions be realized.



Attachment: www.arb.ca.gov/lists/lcfsadvisorypanel-ws/13-rentech_comments_on_presentations_to_carb_lcfs_advisory_board_presentations_jd.doc

Original File Name: Rentech comments on Presentations to CARB LCFS Advisory Board Presentations JD.doc

Date and Time Comment Was Submitted: 2011-07-22 14:42:42



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