Comment Log Display

Here is the comment you selected to display.

Comment 5 for Amendments to the Regulation on the Commercialization of Alternative Diesel Fuels (adf2020) - 45 Day.

First NameRebecca
Last NameBoudreaux
Email Addressrebecca@oberonfuels.com
AffiliationOberon Fuels
SubjectComments on Proposed Amendments to the Alternative Diesel Fuel Regulation
Comment
Alexander “Lex” Mitchell
Manager, Emerging Technology Section 
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812 

RE: Comments on Proposed Amendments to the Alternative Diesel Fuel
Regulation

Dear Mr. Mitchell,

Thank you for your continued work on the Alternative Diesel Fuel
(ADF) Regulation. As you may remember, we supported its creation
and have followed the evolution of the ADF since enacted.  The ADF
regulation is important for companies like ours, bringing
innovative fuels such as renewable DME (rDME) to market, as the
rule provides a pathway by which such fuels can be commercialized.
As part of a $2.9 million California Energy Commission grant
initiated in July 2019, Oberon Fuels will be submitting an ADF
Stage 1 application prior to the testing of DME-powered vehicles in
the next six months. 

The potential ADF amendments as proposed raise some concerns.
Specifically:

• The sweeping nature of this rule change has no precedence and is
inconsistent with other CARB-based fuels, as none are required to
undergo double testing. We understand the need to address specific
issues with specific fuels and additives. We would suggest that if
there are problems specific to certain fuels and additives, those
should be clearly identified and isolated in the rule change
language so as to avoid unintended consequences for innovative
fuels that do not present such concerns. 

• While we understand the challenges associated with the fuel
blends tested, we are concerned that expanding the testing
requirements for fuel additives and formulations as stated could
also mean expanded testing requirements for innovative fuels such
as rDME. This would add another hurdle for innovative, ultra-low
carbon fuels coming to market. In order to move from Research &
Development to Commercialization Stage, innovative fuels are
already required to overcome numerous testing and market barriers.
Adding additional testing requirements could stifle innovation.

• Costs:By requiring two labs to perform the same tests, testing
required would double in costs.

Our request:
• Provide an additional three months for stakeholders to engage
with ARB Staff on this topic and collaborate on a remedy that
addresses your staff’s concerns and our need for flexibility and
innovation in these difficult times.

No one wants unintended consequences of modified certification
requirements. As such, please consider providing additional time to
collaborate with stakeholders like us.

Thank you for your consideration. We look forward to continuing to
work with you on the ADF and bringing innovative fuels to market. 

All the best,

s/ Rebecca Boudreaux, Ph.D.
President, Oberon Fuels

Note: .pdf copy attached

Attachment www.arb.ca.gov/lists/com-attach/15-adf2020-VjlXMwBkVXRXPlM9.pdf
Original File NameOberon Fuels Comments CARB ADF Proposed Changes April 23 2020.pdf
Date and Time Comment Was Submitted 2020-04-23 08:15:34

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


Board Comments Home