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Comment 2 for Comments for the LCFS Method 2A2B applications (lcfs2a2bcomments-ws) - 2nd Workshop.

First Name: Vitor
Last Name: Caetano
Email Address:
Affiliation: Odebrecht Agroindustrial

Subject: Molasses Ethanol (ETHM004)
Dear Srs.,

1. We think there is a misunderstanding in the proposition of the
value for the LUC based emissions for the molasses based ethanol
(...”The proposed value consists of the Brazilian value of 46 g
CO2e/MJ mutiplied by the proportion of fermentable sugars in sugar
cane juice that ends up in the molasses used as feedstock for the
process. That proportion is the mass allocation factor of 0.34”.)
The initial assumptions in the document can not support this
proposition. To put it simply, total LUC emissions are directly
related to the area displaced by sugarcane; the initial assumptions
lead to 34% of the TRS being allocated to molasses,  leading to 34%
of total cane being allocated to molasses, and so 34% of the total
area;  and consequently 34% of the total LUC associated emissions. 

But of course we would only produce 34% of the ethanol we coud
produce with the same total cane (autonomous distillery). So, the
LUC emissions (for molasses production) come down to 34% of the
total, but also the ethanol production; and the ratio g CO2e/MJ
ethanol remains the same (46, at least until changed by ARB). But
of course this would be done to all sugar cane ethanol.
Just remainding the “initial assumptions” used:
“ The allocation method chosen... the total upstream and sugar
production emissions are allocated on the basis of the ratio of the
total reducing sugars (TRS) in the molasses... to the TRS entering
the sugar process for each ton of sugarcane that enters the factory
“ the (bagasse) credit is... assumed to be proportional to the
fraction of TRS in ...molasses to the total amount of TRS in sugar
cane juice.”
2.  Certainly a minor point (with respect to to the first): in this
process, the flow diagram proposed is correct in showing that all
the juice goes to the sugar factory and trough the whole sugar
production process  (although the TRS ratios indicate high sugar
concentration in the molasses, not exhausted molasses).  So, no
juice may by-pass the sugar production and be sent to the

Thank you for the attention.

Best regards.

Vitor Caetano


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Date and Time Comment Was Submitted: 2013-12-23 03:08:59

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