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Comment 2 for Low Carbon Fuel Standard Public Workshop to Discuss Potential Regulation Revisions (lcfs-wkshp-oct20-ws) - 1st Workshop.
First Name: Ken
Last Name: Haney
Email Address: kenneth.haney@crc.com
Affiliation: California Resources Corporation
Subject: LCFS Phase-out of CCS/EOR
Comment:
Below is a suggestion regarding the CARB staff alluding to a future "phase-out" of CCS/EOR under LCFS. Given that CCS with EOR in California (particularly CO2 EOR) will yield a lifecycle oil carbon intensity far below any native or imported crudes, the very last barrel of crude refined/utilized in California should come from in-state CCS with EOR. Any phase-out of CCS with EOR from LCFS should be based on actual crude demand/usage in California rather than forecasts subject to political and/or other influences.
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Date and Time Comment Was Submitted: 2020-10-15 08:14:30
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