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Comment 9 for Comments for the California GREET model in LCFS (ca-greet-comments-ws) - 1st Workshop.
First Name: Tom
Last Name: Willis
Email Address: tom.willis@conestogaenergy.com
Affiliation:
Subject: comments for the Calif greet
Comment:
Mr. Ingram and Mr. Pham, As we have stated in recent comments, Conestoga Energy Partners, LLC is a Kansas based ethanol producer currently relying on sorghum for a significant portion of our annual grain usage. Again, we hope to continue to increase both our ethanol shipments to California and our sorghum usage, as we feel sorghum has an important role to play in helping California meet the greenhouse gas reduction goals set by the LCFS and reducing water usage in irrigated agriculture. We maintain close contact with National Sorghum Producers (NSP) and understand they are submitting comments as well. As NSP does, we strongly encourage you to consider revising the values related to sorghum yield, the sorghum N application rate and the sorghum stover N content. The sorghum stover N content figure is particularly troubling, as it is based on data not comparable to those found in modern commercial sorghum production. As an alternative, we would support NSP’s data and suggested changes. Thank you for the opportunity to comment. Regards, Tom Willis, CEO Conestoga Energy Partners, LLC 1701 N Kansas Ave Liberal KS 67901 620-624-2901
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Date and Time Comment Was Submitted: 2014-10-24 13:35:53
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