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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



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