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Comment 6 for Comments for the California GREET model in LCFS (ca-greet-comments-ws) - 1st Workshop.


First Name: Lyle
Last Name: Schlyer
Email Address: lschlyer@calgren.com
Affiliation: President, Calgren Renewable Fuels

Subject: Comments on LCFS Program - CA-GREET 2.0
Comment:
Calgren Renewable Fuels is a California fuel ethanol producer
engaged in efforts to use more sorghum as feedstock. We feel
sorghum has an important role to play in helping our state meet
carbon reductions goals embodied in the LCFS. As an added benefit,
sorghum significantly reduces water usage. 

We understand the National Sorghum Producers (NSP) are submitting
comments and encouraging you to consider revising several sorghum
metrics. We have worked closely with NSP and respect their
professionalism. NSP believes the values you propose to use for
sorghum yield, sorghum nitrogen application rate, and sorghum
stover nitrogen content are outdated or otherwise incorrect. In
particular, I am told the sorghum stover nitrogen content figure
you propose to use in CA-GREET 2.0 is based on data that is not
representative of modern commercial sorghum production. Thus we
endorse NSP's proposed changes. 

Given it's substantial benefits for Californians, sorghum deserves
a fair shake.

Thank you for giving us the opportunity to comment.

Very truly yours,

Lyle Schlyer
President, Calgren Renewable Fuels

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Date and Time Comment Was Submitted: 2014-10-24 07:32:19



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