Comment Log Display

Comment Log Display

Below is the comment you selected to display.
Comment 1 for LCFS Program Review Advisory Panel (2011) (lcfsadvisorypanel-ws) - 1st Workshop.


First Name: Stephen
Last Name: Kaffka
Email Address: srkaffka@ucdavis.edu
Affiliation: Department of Plant Sciences, UC Davis

Subject: Proposed Corn Oil Biodiesel Ppathway
Comment:
23 February 2011

Mr. John Courtis
Manager, Alternative Fuels Section
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812

Re:   “Detailed California-Modified GREET pathway for Corn Oil
Biodiesel (COB)”_December 14, 2010.

Dear John,

In the proposed Low Carbon Fuel Standard (LCFS) pathway)for Corn
Oil Biodiesel (COB), CARB treats COB as a residue of the starch
ethanol process.  No green house gas costs are attributed to
production of the oil fraction of the corn grain extracted after
starch conversion to ethanol.  Secondly, there does not appear to
be any adjustment of the altered DDGS meal.  DDGS is an important
livestock feed for cattle, hogs and poultry, and an internationally
traded commodity.

I have two concerns about this approach:

1.	Feeds are used based primarily on their energy, protein, fiber
and some secondary properties.  They are combined with other feeds
using these qualities to calculate a total mixed diet or ration. 
These rations are dynamic, sensitive to price, livestock species,
stage of growth and many other considerations.  When corn oil is
removed from DDGS, its energy value will be affected and perhaps
other quality characteristics that could affect livestock
performance like palatability or intake.   At a minimum, a
livestock feeder will have to find some other source of plant  oil
or energy to compensate.  Currently, CARB provides a by-product
feeding credit to adjust for the use of DDGS in livestock feeds and
its displacement of crops for which it compensates.  This comes
from GREET.  While the GREET values are just  approximations for a
far more complicated pattern of use in livestock feeding, they
recognize of that use and estimate associated crop displacement.  
It is not clear to me if livestock performance trials with modified
DDGS have been carried out or even if calculations based on
existing nutritional formulations have been made.  Perhaps they
have and I missed that explanation.  But if not, some accounting
for altered nutritional value must be included.  It is not clear if
de-oiled DDGS will be significantly different from standard DDGS or
if it will effect use by all livestock species equally.  If
differences are significant and result in reduced use of DDGS or
other feed substitutions, then the GHG benefits of using corn oil
may not be real, or as large as estimated by CARB.  In any case,
consistency in methods as far as possible seems to me be an
essential characteristic for the success of the LCFS.  
 
2.	Land Use Change is a result of decisions about which crop to
grow.  COB production likely will increase the value of corn to
ethanol refiners, and it may also influence the price of corn
relative to other crop alternatives as well.  While there are
different ways to proportion production costs to various products,
it seems that all products have such costs, especially in so far as
they influence land use decisions including acres, inputs, and
cultivars, through modifying demand for the feedstock.  Many
ethanol businesses are coops, and the owners include farmers who
produce the grain feedstocks.  But even for growers who are not
coop owners, but sell into the corn grain market, the acreage
decision is affected by price considerations.  This suggests to me
that corn oil should also have a portion of the grain production
costs associated with it.  This is not done in the proposed COB
pathway.  If I understand correctly, the oil simply appears at some
point in the production process, is considered a waste without
alternative uses, and then a Carbon Intensity is calculated based
only on manufacturing costs.  This seems inconsistent to me with
other pathways estiamted by CARB, risks over- or undervaluing COB,
and compromises the ethanol calculations used in the LCFS.

Critical to this entire consideration is the magnitude in the
changes to DDGS and the effect on demand for corn grain that COB
might induce.  If they are small, then, these are not important
concerns.  But the issue of consistency remains.  

Thank you for considering these comments.

Best wishes,

Steve Kaffka
Department of Plant Sciences
University of California
Davis, CA 95616
srkaffka@ucdavis.edu 

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2011-02-23 14:45:07



If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.


Board Comments Home

preload