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Comment 16 for Comments for the California GREET model in LCFS (ca-greet-comments-ws) - 1st Workshop.


First Name: Andy
Last Name: Foster
Email Address: andy.foster@aemetis.com
Affiliation: Aemetis Advanced Fuel Keyes

Subject: LCFS Sorghum Comments
Comment:
Mr. Ingram and Mr. Pham,
 
As we stated in recent comments, Aemetis Advanced Fuels Keyes is a
California-based ethanol producer currently engaged in efforts to
use more sorghum. Again, 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 on irrigated acres in
California.
 
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,
 
Andy Foster
EVP and President
Aemetis, Inc.

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Date and Time Comment Was Submitted: 2014-10-24 15:32:24



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