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Comment 34 for Low Carbon Fuel Standard Public Workshop to Discuss Potential Regulation Revisions (lcfs-wkshp-oct20-ws) - 1st Workshop.


First Name: Antonio
Last Name: ValleNeto
Email Address: antonio.valleneto@bunge.com
Affiliation: BUNGE

Subject: soybean faming energy factor in GREET
Comment:
The soybean farming energy in GREET comes from a USDA survey and is
the national average. The original USDA data source reports the
values at the state level. 

Would CARB consider the use of the state level data to better
reflect the actual carbon intensity of specific soybean oil
producers if the soybean oil producer was able to document where
the soybeans were grown? 

In concept this is the same as the use of regional electricity
grids.

Thanks.

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Date and Time Comment Was Submitted: 2020-11-05 07:04:45



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