Comment Log Display
Below is the comment you selected to display.
Comment 7 for Comments for the California GREET model in LCFS (ca-greet-comments-ws) - 1st Workshop.
First Name: John
Last Name: Duff
Email Address: john@sorghumgrowers.com
Affiliation:
Subject: National Sorghum Producers Comments on the LCFS Program – CA-GREET 2.0
Comment:
October 24, 2014 Cal/EPA Headquarters Building 1001 “I” Street Sacramento, CA 95812 RE: Comments on the LCFS Program – CA-GREET 2.0 Mr. Ingram and Mr. Pham, National Sorghum Producers (NSP) is a trade association representing the interests of over 50,000 sorghum producers on issues related to legislative and regulatory policy in Washington as well as various state capitals. NSP led efforts to secure an advanced biofuel pathway for sorghum under the RFS2 and has performed extensive analysis on several models and datasets over the last four years, including several datasets similar to those used by the Argonne National Laboratory (ANL) as well as the ARB in modeling the CI of sorghum ethanol. NSP applauds the ARB for undertaking an extensive update of the LCFS, but we have serious concerns about several of the assumptions underlying the portions of the GREET model used to estimate sorghum CI. We have been in close contact with personnel at the ANL regarding these concerns and present them in the attached comments (our comments are contained in the attached file titled "National Sorghum Producers CA-GREET 2.0 Comments"). Our concerns in brief: • Sorghum yield. Sorghum yield has been lowered based on data gathered in a historic drought. Sorghum yields are unlikely to ever again be as low as they have been over the last few years, so this value should be left unchanged. • Sorghum farming energy use. The energy use value should ultimately reflect the fact that a large percentage of producers practice no tillage agriculture which correlates to significant fossil fuel savings on-farm as well as the fact that grain sorghum is not dried using fossil fuels. • Nitrogen application rate. Nitrogen application rates have not changed. This is due to fertilizer recommendations remaining the same and a grain sorghum harvest ratio calculation error. With forage sorghum acres excluded from the NASS-published acreage figures, the nitrogen application rate is similar to that used by the ARB in the 2010 pathway. • N2O emissions from sorghum stover. This area is especially concerning, as it has very significant CI effects and its applicable model portions are based on sorghum genotypes not used in commercial sorghum production. As a result, these genotypes have yields and harvest indices completely unlike anything that would be found in modern sorghum production, leading to a much higher score in this area. Using alternative data from actual hybrids used in commercial sorghum production results in an N2O emissions from stover value much lower and closer to the one used by the ARB for corn, which would be expected given the two crops' compositional similarities. Thank you for the opportunity to provide feedback and make suggestions. We feel with these changes, sorghum ethanol can play an even larger role in helping California meet the greenhouse gas reduction goals set by the LCFS while at the same time promoting the use of water-sipping crops like sorghum. Please do not hesitate to let me know if you have any questions. Regards, John John Duff Analyst National Sorghum Producers 4201 N. Interstate 27 Lubbock, TX 79403 Phone: (806) 749-3478
Attachment: www.arb.ca.gov/lists/com-attach/8-ca-greet-comments-ws-AmwAZwN2VmxWP1Q6.zip
Original File Name: National Sorghum Producers Comments and Supporting Documents.zip
Date and Time Comment Was Submitted: 2014-10-24 09:13:04
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.