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Comment 6 for Amendments to the Regulation on the Commercialization of Alternative Diesel Fuels (adf2020) - 45 Day.

First NameJennifer
Last NameCase
Email Addressjennifer@newleafbiofuel.com
Affiliation
SubjectPublic Comments regarding ADF Amendments by New Leaf Biofuel
Comment
Good morning to everyone at CARB.

My name is Jennifer Case.  I have owned and operated a biodiesel
plant here in the disadvantaged community of Barrio Logan in San
Diego for the last 14 years.  I’m absolutely shocked and very
disappointed to have to be here today to oppose these ADF
amendments in the midst of a pandemic that has forced our company
into the worst economic situation since our founding. 

New Leaf was founded as a woman-owned company, started by my
friends and I in order to reduce the use of fossil fuels in our
beautiful state by producing biodiesel from used cooking oil.  Our
fuel has enjoyed one of the lowest CIs in the program.  Despite our
best efforts to contribute to California’s goals of reducing
Greenhouse Gas Emissions, it seems that every time we turn around,
we are fighting another uphill battle for our survival.

Right now, we are in severe economic distress.  Our feedstock has
dried up and fuel prices are unprecedentedly low.  I have spent
every day of the last month staring at my financials trying to
figure out how to keep my employees working despite this
unprecedented time.  Despite being one of the smaller players in
the space, our employees enjoy high wages, 401ks, free health
insurance and a bunch of other benefits that make us a great place
to work.  But right now, all of that is being threatened.  First by
the pandemic, and now by these hastily considered amendments that
threaten to put a final nail in the coffin of small producers.

If the regulation as proposed is passed, our business will be
finished.  I’m not being dramatic here.  

We do not have the buying power to buy Renewable Diesel and blend
it at a high ratio with every gallon of biodiesel we produce. 
There are only a handful of RD suppliers, and only one very small
one in California.  The largest RD supplier in the world in
Singapore, expressly forbids biodiesel to be blended with its RD
for business reasons.

So we are left with only a couple other RD producers that won’t
even take my phone call.  If you insist on making sure that there
is a certain amount of RD blended into the fuel supply, GREAT.  We
support that.  But it must be on an aggregate level.  It cannot be
in each physical gallon.  And as others have stated here, the ratio
in this proposed regulation is incorrect.  

Even if we were able to obtain RD to blend into our fuel,
logistically, it would be impossible at every location where
biodiesel is currently being used.  There simply is not enough RD
available, and the state lacks the infrastructure at this point for
it to be widely distributed.  Furthermore, the 2-lab test is overly
burdensome to our industry and imposes far harsher restrictions on
testing than the fuel we are mitigating. 

We absolutely need more time to work on this.  Let us save our
businesses from death by pandemic and then work with you on an ADF
regulation that we can survive.  We all want the same thing here,
and I’m sure your heart is in the right place. But the math,
science and sales impacts are subject matters that require input
and collaboration from all stakeholders.  Without our input, you
are going to kill us, and in turn, severely harm the LCFS program,
which currently gets 20% of its credit generation from biodiesel. 


Jennifer Case
Founder & President
New Leaf Biofuel, LLC

Attachment www.arb.ca.gov/lists/com-attach/16-adf2020-VDVXNQdgWFQEYQJt.docx
Original File NameADF comments - New Leaf.docx
Date and Time Comment Was Submitted 2020-04-23 08:38:21

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


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