Clerk of the
Board
California Air
Resources Board
1001 I
Street
Sacramento, CA
95814
October 13,
2022
Dear Chair
Randolph and Board Members,
Global Clean
Energy is a California-based renewable fuels innovator producing
ultra-low carbon renewable fuels from patented nonfood camelina
varieties. We thank the California Air Resources Board (CARB) for
allowing us the opportunity to comment on the Proposed Advanced
Clean Fleets (ACF) Regulation for medium- and heavy-duty
fleets.
Global Clean
Energy is committed to advancing climate reduction targets to
improve air quality throughout the Golden State using our ultra-low
carbon camelina-based renewable fuels. We appreciate
CARB taking steps to address transportation-related
emissions.
We commend
CARB’s efforts to reduce harmful emissions from motor
vehicles through the Proposed ACF Regulation. We are equally
supportive of staff’s recognition that zero-emission vehicle
transition is better suited for smaller fleets. While CARB
continues investigating a range of tools that can address medium-
and heavy-duty vehicle fleets in an equitable and effective way, we
respectfully recommend CARB further incentivize the use of
renewable diesel in its push to achieve carbon neutrality through
the Proposed ACF Regulation.
Renewable diesel
is a clean energy technology option that will improve air quality
in the near-term but also deliver on longer-term climate goals. As
your proposed regulation confirms, the use of low carbon fuels
contributes to the reduction of GHG emissions from the
transportation sector: “Given that internal combustion engine
(ICE) vehicles from legacy fleets will likely remain on the road
for some time, even after all new vehicle sales have transitioned
to ZEV technology, low carbon liquid fuels may continue to be used
during this period of transition especially for more challenging
use cases, and sectors such as aviation, locomotives, and marine
applications” (Pg. 109). We encourage CARB’s adoption
of ultra-low carbon renewable diesel incentives for medium- and
heavy-duty vehicles and other sectors that are harder to
decarbonize such as rail, aviation, ocean-going vessels and
stationary applications.
The Proposed ACF
Regulation provides that mobile transportation sources and the
fossil fuels that power them are the largest contributors to the
formation of ozone, GHG emissions, PM2.5, and toxic diesel PM.
Renewable diesel significantly reduces
criteria pollution, including NOx and PM, as well as reducing GHG
emissions by up to 85% (depending on feedstock – camelina
feedstock fuels reduce GHG emissions by over 90%). In fact,
according to CARB’s Renewable Diesel Workshop¹, using
renewable diesel on all tier 0-4i equipment in the San Joaquin
Valley (2025) would reduce NOx emissions by 0.55 tpd and PM2.5
emissions by 0.073 tpd. Renewable Diesel has fewer GHG and local
emissions than both traditional diesel and biodiesel fuels, acts as
a drop-in replacement for modern traditional diesel engines with no
blending required, and unlike ZEVs, does not require largescale
infrastructure replacement. In addition, renewable diesel is
readily available across the majority of California and is at cost
parity with CARB ULSD.
Further, the
heightened use of renewable fuels alleviates public concerns around
the availability and rollout of public and private ZEV
infrastructure, including both charging and hydrogen stations, and
the grid’s ability to meet the steadily growing electrical
demand generated by the Proposed ACF Regulation and other rules
promoting electrification. Renewable diesel is also a valuable tool
to cost-effectively complete the transition for remaining fleets
that are more dependent on purchasing trucks on the secondary
market.
We encourage
you to prioritize the use of renewable diesel more readily in
California. There are no technical, supply, or financial reasons
why medium and heavy-duty vehicles cannot switch to renewable
diesel use rather than ZEVs to support CARB’s carbon
reduction objectives. By encouraging renewable fuels’
heightened use in medium and heavy-duty vehicles, CARB can limit
economic impacts on businesses that would otherwise have to replace
their existing vehicle fleets while achieving its environmental
objectives of reducing emissions.
Global Clean Energy’s primary
renewable fuel feedstock, our patented camelina, is a lipid-based
feedstock that is nonfood, grows between traditional crop cycles on
dryland farms, and does not contribute to land use change. Indeed,
our patented camelina varieties were issued a first-of-its kind
LCFS pathway by CARB in 2015. Further, camelina has the potential
to be the lowest carbon renewable fuel feedstock on the market.
Camelina-based renewable fuels produced by Global Clean Energy have
an ultra-low carbon intensity (CI) score that has the potential to
go below zero.
With more than 100 employees, our
Bakersfield Renewable Fuels Refinery is already actively
contributing to the “Just Transition” from fossil fuels
to clean energy careers. Once our Bakersfield Renewable Fuels
Refinery (nameplate capacity of 15,000 barrels per day) commences
operation in the coming months, we expect initial production of
approximately 150 million gallons per year. Our renewable fuels
will be readily available to the California market through existing
distribution agreements, and we expect the San Juaquin
Valley’s agricultural and trucking sectors to consume much of
what we produce. Moreover, we expect our renewable fuels to have a
direct and beneficial impact on an area of the Golden State that
the Proposed ACF Regulation notes has the among the most critical
air quality challenges in the state. Our fuels can play a
meaningful role in the clean air solution for this region and other
regions throughout California.
We
appreciate CARB taking the benefits of renewable fuels into account
in its rule making process and encourage you to consider
incentivizing the use of ultra-low carbon renewable diesel fuels in
medium- and heavy-duty vehicles as well as other sectors
such
as rail, aviation, and ocean-going vessels to advance
California’s clean energy goals.
Sincerely,
Amanda Parsons
DeRosier
Vice President of
Public Affairs and Investor Relations
Global Clean
Energy | www.GCEholdings.com
562-233-5146 |
Amanda.DeRosier@gceholdings.com
- https://ww2.arb.ca.gov/sites/default/files/2021-09/ORD_Amendment_Workgroup-Renewable_Diesel.pdf