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Comment 169 for General Comments for the GHG Scoping Plan (sp-general-ws) - 1st Workshop.


First Name: David
Last Name: Rubenstein
Email Address: drubenstein@CaliforniaEthanolPower.com
Affiliation: California Ethanol & Power, LLC

Subject: California Ethanol & Power-Comments to Draft AB 32 Scoping Plan
Comment:
Mary Nichols, Chair
California Air Resources Board
1001 I Street
Sacramento, CA  95814

Re:  Comments on the Draft AB 32 Scoping Plan

Dear Ms. Nichols and members and staff of the California Air
Resources Board,

California Ethanol & Power, LLC (CE&P) is a company that was
formed to produce energy in the Imperial Valley from locally-grown
sugarcane. Our plan is to use “off the shelf” ethanol technology,
which has been thoroughly proven in Brazil, to convert sugarcane
grown on about 36,000 acres of surrounding farmland in Imperial
County into approximately 60 million gallons of fuel-grade
ethanol. The facility is also scheduled to combust bagasse (the
shredded sugarcane stalks left over once the juice has been
extracted) and field waste to potentially produce up to 50
megawatts of renewable electricity.  

Our CE&P sugarcane ethanol is designed to be among the lowest
carbon fuels in California.  Su-garcane derived ethanol is already
one of the lowest carbon fuels produced; it has a documented 80%
GHG emission reduction when compared to the life-cycle of regular
gasoline. The CE&P sugarcane to ethanol process, however, is a
multi-faceted project and involves additional “closed-loop”
strategies and technologies that might further reduce the carbon
footprint of our fuel.  

The purpose of this comment letter is to outline those strategies
and technologies within the recommended measures found in the
Draft AB 32 Scoping Plan and to request further clarification on
scoping issues that will not only be beneficial to CE&P, but to
the State of California as it strives to meet its GHG goals.   

Renewable Portfolio Standard
Not only will CE&P produce enough power for its own facility needs
but it also has the opportu-nity to produce up to 50 Mw of excess
power that will assist utilities in meeting the aggressive RPS
goal of 33 percent by 2020. CE&P would urge the California Air
Resources Board (ARB) to encourage the California Energy
Commission (CEC) and the California Public Utilities Com-mission
(CPUC) to streamline the approval of projects like this that have
the ability to generate excess renewable power as well as meet the
local air district standards for non-attainment.

Low Carbon Fuel Standard 
The fuel cycle impacts (including multi-media impacts) of
sugarcane to ethanol have been well documented and reported.
Additionally, CE&P’s initial operation will incorporate the latest
agri-cultural techniques, currently being transitioned to in
Brazil, which further enhance the fuel’s low carbon footprint.
CE&P would like to have the opportunity to provide ARB additional
analysis on certain carbon reducing activities that are specific
to our proposed facility.  

Important to CE&P’s overall life cycle impact is the consideration
of the carbon that is emitted during the fermentation process. CE&P
carbon dioxide is released during the processing of local-ly grown
crops. This is different from the carbon dioxide produced from
corn to ethanol facilities, where crops are railed in from out of
state. CE&P, therefore, would like to propose to ARB that the
carbon dioxide emissions from the fermentation process are carbon
neutral because it is part of the short-term CO2 cycle of the
biosphere.  

In an effort, however, to reduce those carbon emissions, CE&P is
evaluating the capture of this carbon dioxide for industrial
refrigeration and other types of innovative uses.  For example,
there is developing technology that allows CO2 emissions to be
absorbed through algae plantations. CE&P will continue to assess
this technology and others and would also look toward ARB in
assisting industry in evaluating those technologies for carbon
sequestration.  

Water 
CE&P will undertake measures to increase water use efficiency and
re-use within our plant de-sign. CE&P is committed to water
recycling and will be interested in the participation of
estimat-ing and documenting the GHG reduction from water
efficiency efforts.   

Recycling and Waste  
As with water, CE&P is committed to the recycling of its organic
by-products. The prospect ex-ists for CE&P to generate and capture
methane emissions. ARB should assess and state the op-portunity to
scope the reduction of methane emissions from other types of
industrial activities as well. CE&P would be interested in
exploring with ARB programs and initiatives that promote more
innovative uses for captured methane; such as pipeline quality
natural gas, compressed nat-ural gas for fuel, and fuel cell
technology.  

CE&P is also planning on utilizing the by-products of the
sugarcane process to produce various types of organic fertilizers.
These organic fertilizers will be applied to our sugarcane fields
and will offset the carbon emissions from petrochemical derived
fertilizers (i.e. nitrogen) that are usually used. CE&P proposes
to include this offset as part of the life cycle impact of our
fuel and asks that ARB further scope the CO2 offsets of replacing
chemical fertilizers with recycled or-ganic fertilizers.  

Agriculture 
Sugarcane is a perennial crop and is one of the highest carbon
absorbing crops grown in California. CE&P wishes to work with ARB
in developing sound quantification protocols on the carbon
sequestration of sugarcane. As stated above, the sugarcane and its
residual biomass will be com-busted within emission limits for
onsite power and for renewable power to the electric grid. Excess
biomass will be utilized either as a fuel at another planned power
production facility or as cattle feed to support the existing
markets. Since the power will be produced through the com-bustion
of locally grown biomass, we request that ARB confirm through
their scoping that the combustion of this biomass is carbon
neutral. By combusting the locally grown sugarcane derived
biomass, CE&P is able to offer more of a “closed-loop” process
that promotes the return of the energy value of the crop back to
the area it is grown. Special consideration should be given to
agricultural projects similar to CE&P which capture and advance
this process.

CE&P is thankful for the opportunity to comment on the Draft AB 32
Scoping Plan in relation to our proposed project.  We believe our
project is consistent with the ambitious reductions laid out in AB
32 and we are excited about the opportunities our project will
bring to Imperial Valley and the State of California. We look
forward to working with ARB as we develop our project and we hope
that through the AB 32 process we can demonstrate that production
of energy from sugarcane is “growing energy the right way”.

Please feel free to contact me at 310/545-8887 or
drubenstein@CaliforniaEthanolPower.com if you have any questions
or concerns regarding our project.

Respectfully submitted,

 

David R. Rubenstein
Chief Operating Officer
California Ethanol & Power, LLC

sugarcane: growing energy the right way

Attachment: www.arb.ca.gov/lists/sp-general-ws/381-cep_comments-ab32scoping.pdf

Original File Name: CEP Comments-AB32Scoping.pdf

Date and Time Comment Was Submitted: 2008-08-01 11:24:03



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