Comment Log Display

I am inquiring as to whether ARB will consider changing the number
of states which can use default distances for grain receipts in
CA-GREET 3.0 pathway submissions.  

The 9 states which currently receive this allowance were determined
based on an ANL study from 2003.  Over the past 17 years, states
like Kansas and North Dakota have made great strides in improving
their farming practices and grain production.  Kansas, in
particular, is now the 6th largest corn producing state and the
largest producer of grain sorghum.  North Dakota is now using corn
to diversify their crop rotations for healthier soil and improved
yields and is easily in the top 10 producing states.  

Ethanol producers in Kansas and North Dakota receive thousands of
grain trucks every month.  Non-Midwestern States have to track
mileage and origination data on all their grain receipts whereas
Midwestern States may need to track some origination data to ensure
compliance but can largely use default data.  

As we get into a more intense reporting and compliance atmosphere,
ethanol producers in non-Midwestern States seem to face a more
rigid regulatory hurdle than those grandfathered into "Midwestern
States" status.  I would ask that ARB update the definition of a
"Midwestern States" to reflect more recent corn/grain production
data so that ethanol production facilities in major production
regions can be treated equally.