Comment Log Display

Element Markets is a long-time driver in various AB32 initiatives,
including the supply of low-carbon transportation fuel solutions
under the LCFS program. We kindly request that CARB perform an
extensive evaluation of carbon intensity effects of feedstock
production under the LCFS program and allow for user-specific
inputs, especially as it pertains to agriculture-derived fuels. We
believe it important for improvements to the agriculture value
chain to be considered in GREET analysis in a comprehensive manner
as opposed to the default pathways currently in mandatory use.
Practices such as no-till, regenerative farming, fertilizer
production alternatives and optimized fertilizer application have a
tremendous effect on the sustainability of fuel production and
agriculture as a whole. While we understand that some of these
areas are complex with uncertainties to be mitigated, we believe
there is tremendous stakeholder engagement and know-how that can
achieve robust advances towards AB32's goals. Also, we believe that
the vast area of farming practices and fertilizer production & use
lends itself to a differentiated approach, where significant
achievements may be safely reaped from "lower hanging fruits" in a
short timeframe, while other topics may need more enduring work
with stakeholders. Accordingly, we kindly ask that CARB identify
multiple areas within the general scope of fertilizer & farming
practices that can advance in parallel, independently from each
other for efficiency.