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Comment 8 for 2022 Scoping Plan Update - Scenario Concepts Technical Workshop (sp22-concepts-ws) - 1st Workshop.


First Name: Graham
Last Name: Noyes
Email Address: graham@noyeslawcorp.com
Affiliation: Noyes Law Corporation for Gevo

Subject: Scenario Concepts Technical Workshop Scoping Plan Comment of Gevo
Comment:
Dear Executive Officer Richard Corey,

Attached please find the comment of Gevo regarding the Scenario
Concepts Technical Workshop.  In particular, the comment draws
attention to what appears to be a shortfall in the modeling
framework:  the lack of recognition of the vast potential for the
agricultural sector to sequester carbon in soil.  The comment
recommends that CARB review the modeling on this specific point,
and, in the event that soil carbon is overlooked or minimized, make
necessary improvements to the modeling approach.  Through
recognition of the potential CO2 reduction opportunities that soil
sequestration presents, CARB will facilitate achievement of
California's goal of carbon neutrality by 2045.  Gevo and other low
carbon fuel industry leaders are already sourcing feedstocks from
low carbon farms to produce fuels but there is great potential to
expand these activities.

If there are any problems with transmission or requested follow up,
please contact me.  Thank you for your assistance.

Best Regards,

Graham Noyes
Noyes Law Corporation for Gevo 

Attachment: www.arb.ca.gov/lists/com-attach/8-sp22-concepts-ws-VWddBFYkVmBSJARw.pdf

Original File Name: 2 Sept 2021 Gevo Comment RE Scoping Plan Modeling.pdf

Date and Time Comment Was Submitted: 2021-09-02 13:24:30



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