Comment Log Display

Dear Board Members;

Green Plains Inc. (NASDAQ:GPRE) is a leading biorefining company
focused on the development and utilization of fermentation,
agricultural and biological technologies in the processing of
annually renewable crops into sustainable value-added ingredients.
This includes the production of cleaner low-carbon biofuels and
renewable feedstocks for advanced biofuels. Green Plains is an
innovative producer of Ultra-High Protein and novel ingredients for
animal and aquaculture diets to help satisfy a growing global
appetite for sustainable protein.

In general, Green Plains supports the LCFS program and these
proposed amendments, with some notable exceptions. We support
CARB's increase in the stringency of the program to reduce
emissions and decarbonize the transportation fuel sector. Reduced
credit values in recent years due to over-compliance with the
program have to some extent slowed investments in renewable fuel
production and research into new fuels. Greater certainty around
credit values being supported would encourage investment from
companies like ours, and improve access to and terms for credit to
execute on these investments. We support both the near-term
step-down in the CI benchmark in 2025, as well as the Automatic
Accelerator Mechanism (AAM) as a means to drive continued
innovation and development in the biofuels sector, and urge CARB to
consider even more aggressive reductions, which we believe are
achievable.

We oppose capping vegetable oil feedstocks for biodiesel and
renewable diesel production, and strongly oppose including inedible
distillers corn oil with other virgin vegetable oils. The renewable
corn oil we produce is a low carbon intensity feedstock that is not
fit for human consumption without further refining, and should not
be included in any consideration of limiting these feedstocks. The
recent surge in the importation of so-called "Used Cooking Oil"
from China and elsewhere would likely be exacerbated if
sustainable, traceable domestic feedstocks are limited, and there
are questions around the authenticity of the "UCO," which some have
alleged could include some quantities of virgin palm oil. 

We opppose the continued exemption for intrastate fossil jet fuel,
and urge CARB to reconsider the origialy proposel to eliminate this
exemption. Airlines need to decarbonize and we are helping them to
transition to new clean fuel alternatives. Today, our inedible
distillers corn oil is a low-CI feedstock for producing SAF and
renewable diesel, and when carbon capture and sequestration of our
biogenic carbon dioxide is deployed beginning in 2025, our
decarbonized ethanol will be a scalable feedstock for airlines to
utilize.
We applaud CARB rejecting an arbitrary cap on crop-based fuels.
Regarding suggested changes to sustainability certification for
crop-based fuels, we ask the board to carefully consider the
reporting burdens and costs that could result from a new
verification scheme. In general, we do not agree with the premise
that U.S. crops displace grasslands, forests and wetlands, but
recognize concerns of stakeholders and the desire for greater
certainty. 

The crops we process into low carbon biofuels and feedstocks for
advanced biofuels, primarily corn, is all grown on cropland that
was not converted from wetlands, forests or grasslands in
accordance with federal Renewable Fuels Standard requirements.
Productivity of corn in particular on a bushel per acre basis has
increased dramatically, so fewer acres of cropland are required
each year to generate the same or greater volumes of production.
Additionally, efficiency of crops has greatly improved, so
necessary inputs of fertilizer and water on a per bushel basis
continue to decline, benefitting soil health, water quality, and
ultimately reducing the carbon-intensity of the feedstock and by
extension the finished biofuels. Likewise, advances in agronomic
practices and enhanced understanding of plant and soil ecosystems
have expanded the adoption of climate smart agricultural practices
such as conservation tillage and cover crops, ultimately keeping
more carbon in the soil and reducing the carbon-intensity of the
feedstock and finished biofuels.

That being said, we are not opposed to pathway holders being
required to track our crop-based feedstocks to their point of
origin, and have independent certification of same, so long as the
tracking requirements are not too onerous or costly. As noted
above, all of the corn we process into ethanol and inedible
distillers corn oil has had to comply with prior converted cropland
requirements under the federal Renewable Fuels Standard. Likewise,
we urge CARB to review and revise the quantification methods for
crop-based biofuels to better reflect yield, cultivation and land
use practices of crops used to produce fuels that accurately
accounts for advances already made and recognizes the potential
climate benefits of field-based agronomic practices.

We appreciate CARB's consideration of these comments, and commend
you for your ongoing commitment to strengthening the LCFS.

Regards,




Devin Mogler
SVP Corporate & Investor Relations
o/b/o Green Plains Inc.