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Comment 349 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameAmanda
Last NameParsons DeRosier
AffiliationGlobal Clean Energy
SubjectComments on 2022 Scoping Plan

Hello -

I am logged onto the 12/15 CARB Board Zoom meeting and have had my virtual hand raised for mulitple hours. Your representative called my name at approximatly 2:40 p.m. but my microphone was never opened to allow me to speak. Below please find my planned spoken remarks:


My name is Amanda Parsons DeRosier and I’m here representing Global Clean Energy. Thank you for accepting our comments today. 


Global Clean Energy is a California-based renewable fuel innovator with offices in Torrance and a renewable fuels refinery in Bakersfield (a disadvantaged community). 


Sustainable agriculture and low carbon renewable fuels are important to our clean energy future and we appreciate you recognizing this within the scoping plan. For the first time, this scoping plan calls for renewable fuel feedstock restrictions to avoid “unintended consequences” such as the “expanse of global deforestation, unsustainable land conversion, or adverse food supply impacts.” 


Global Clean Energy is unique in that we will produce ultra-low carbon renewable fuels using a new crop called camelina, which contributes to none of these concerns. 


Unlike other renewable fuel feedstocks, camelina is nonfood. It has quick maturity, drought tolerance, pest tolerance, promotes biodiversity, sequesters carbon as it is grown, and provides land benefits similar to cover crops. Importantly, camelina also does not displace food crops when grown - rather, it grows on fallow farm land between crop cycles - providing additive revenues to farmers and rural agricultural communities.


With these unique traits, camelina does not contribute to the food vs. fuel debate or cause indirect land use change. It provides sustainable agriculture benefits as it is grown and clean air benefits from the fuels it produces. Further, camalina has the potential to be the lowest carbon renewable fuel feedstock on the market.


Renewable fuels made from intermediate feedstocks like camelina can play a key role in propelling California toward reaching carbon neutrality by 2045. We encourage CARB to recognize that not all virgin oil feedstocks are created equal and urge you to create incentives for the use of non ILUC crops like camelina for renewable fuel production as you implement policies guided by this scoping plan. Thank you. 

Original File Name
Date and Time Comment Was Submitted 2022-12-15 14:54:13

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