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Comment 19 for 2022 Scoping Plan Update - Short-Lived Climate Pollutants Workshop (sp22-slcp-ws) - 1st Workshop.


First Name: James
Last Name: McVaney
Email Address: jim@carbonsinkllc.com
Affiliation: Carbon Sink LLC

Subject: Comments in response to the 2022 Scoping Plan Update - Short-Lived Climate Pollutants Work
Comment:
 The Honorable Liane M. Randolph Chair, California Air Resources
Board P.O. Box 2815
Sacramento, CA 9584
Re: Comments of Carbon Sink LLC on the California Air Resources
Board's 2022 Scoping Plan Workshop on September 8, 2021, on
Short-Lived Climate Pollutants
Dear Chair Randolph:
On behalf of Carbon Sink LLC, a Maryland-based company committed to
developing large-scale projects that will produce ultra-low carbon
fuels and chemicals from carbon dioxide captured from the
atmosphere and industrial processes, I am pleased to submit these
comments in response to the
Requested Policy Change (summarized): grant parity to renewable
fuels produced at facilities that capture CO2 and recycle it into
products that displace fossil fuels with those that sequester, or
"landfill", CO2 in geologic formations.
Justification (summarized): recycling CO2 from biofuels plants into
renewable, sustainable fuels and chemicals will directly displace
fossil fuel use and its associated emissions. Carbon capture and
sequestration stores about .88 tonnes of CO2 for each tonne of CO2
captured (CO2 is emitted in the capture, liquefaction,
transportation, and injection). By comparison, CO2captured from the
same plant and recycled into fuel to replace bunker fuel in ships
will result in a net of 1.0 to 1.9 tonnes of CO2 from crude oil
that will not be released into the atmosphere, and as much as 2.5
tonnes if the CO2 is captured and used in the manufacture of
materials.
At Carbon Sink we believe the best pathway to reducing greenhouse
gas concentrations in the atmosphere is by finding productive,
commercial uses for those gasses that can displace future fossil
energy extraction, processing, and combustion. While government
policies and incentives can create markets for low-carbon
solutions, innovation and efficiency improvements will drive down
the cost-curve for these solutions and make them both
environmentally and economically sustainable. Carbon Sink's model
is to take advantage of increasingly affordable electricity from
wind energy systems to produce "green hydrogen" via electrolysis of
water. The zero-carbon H2 will be combined with biogenic CO2
captured from existing ethanol plants in the U.S. Midwest to make
September 22, 2021
 2022 Scoping Plan Update - Short-Lived Climate
 Pollutants Workshop, held on September 8th 2021.
Carbon Sink LLC 1521 N Greenbrier St, Arlington VA 22205 (800)
583-5223

 green methanol (eMethanol) which can be sold into the shipping
sector to replace bunker fuel, to the railroads to displace diesel,
to intra-coastal shipping and transportation to also displace
diesel used in ferries, harbor tugs, barge tugs and other
near-shore transportation, for use in direct-methanol fuel cells
for transportation and power generation and for use in the
materials sector, where it will be converted to building materials,
auto parts and other long-lived products that will serve to
sequester the carbon that we initially extracted from the
atmosphere.
As we establish our business, we will seek to expand into other
sectors to capture and utilize CO2 to produce eMethanol. The
second-generation model will focus non-biogenic CO2 from ammonia
manufacturing, natural gas processing, and certain chemicals
plants. The third-generation will use CO2 from Direct Air Capture
(DAC) plants as they become more economically viable. Imagine, a
network of plants, some in remote, windy locations around the
world, that produce eMethanol from the air.
About Methanol and eMethanol
Methanol is the simplest form of alcohol, with the chemical formula
of CH3HOH. It is the most "hydrogen-dense" liquid, with 4 hydrogen
atoms to 1 carbon atom and 1 oxygen atom. It is miscible in water.
Most methanol produced in the world today is from either natural
gas or coal and is ether used in the production of various
materials like polymers, plastics, adhesives, and fibers, which are
then used to make auto parts, electronic devices, plywood, and
clothing, respectively. It is also blended with gasoline in Europe
and China, sometimes used in methanol-powered engines, and
increasingly as a replacement fuel in shipping.
eMethanol is chemically identical to conventional, aka "grey"
methanol, but is produced using renewably produced hydrogen and
captured carbon dioxide. It is known as "e"Methanol because it is a
member of the "eFuels" family, a grouping of emerging fuels that
are dependent upon utilization of renewable electricity.
Because it is a liquid at ambient temperatures and pressures, it
can be shipped easily via truck or rail, and stored in tanks used
for alcohol storage, or transported over dedicated pipelines. The
Methanol Institute is a good source for information on the
properties, market and uses of both methanol and eMethanol, which
can be accessed at www.Methanol.org.
Carbon Sink Model and the Value to California
As indicated above, Carbon Sink will develop plants that will use
CO2 from existing ethanol plants to make eMethanol. Our plants will
be co-located with ethanol production, which will allow us to
optimize the operations of both facilities. As an example, our
 Carbon Sink LLC 1521 N Greenbrier St, Arlington VA 22205 (800)
583-5223

 hydrogen and eMethanol production processes will produce excess
heat that can be used to displace some natural gas use in the
ethanol production process, lowering the carbon intensity of the
ethanol.
However, the greatest value of our plants will be in the recycling
of CO2 from the ethanol fermentation process into a zero or
near-zero carbon fuel. Currently, this CO2 is vented back to the
atmosphere, but our process will recycle into a product, eMethanol,
that will displace fossil-derived fuels and chemicals. And while
this CO2 will return to the atmosphere if it is combusted, it will
prevent the extraction, refining and combusting of crude oil and
the associated release of carbon that was previously deep in the
earth.
Currently, the California Low-Carbon Fuels Standard does not give
credit for recycling CO2, although it does give emissions credits
for sequestering CO2 from the ethanol production process. While
sequestering CO2 from the ethanol production process will reduce
GHG gasses in the atmosphere, it wastes valuable, pure CO2 that
could be used to displace petroleum use and result in greater
reductions of atmospheric carbon dioxide.
Proposed Policy Change
In calculating the carbon intensity of a biofuel, such as ethanol,
sold under the LCFS, CARB should give equal value for CO2 captured
and recycled into commercially saleable products that displace
petroleum products, as is given to biofuels produced in plants that
capture and sequester the associated CO2 in geologic formations. In
doing so, the biofuels from such plants should be able to realize
the same carbon intensity reductions under the LCFS as biofuels
produced at plants that sequester their CO2 in geologic
formations.
Greenhouse gas reductions because of this proposed change
Productive utilization of captured CO2 from industrial sources,
whether biogenic or anthropogenic, will be the most effective
solution for reducing carbon concentrations in the atmosphere
because it can be self-sustaining. By making products we use every
day from captured CO2 rather than from hydrocarbons extracted from
the earth, we can turn things we currently view as contributors to
climate change into solutions for addressing climate change.
However, the technologies and processes for converting CO2 into
products will not become a reality if we continue to give greater
incentives for the sequestration of CO2 in the ground rather than
encouraging its use, as is the effect of the current LCFS
structure.
Under current LFCS rules, an ethanol plant that captures and
sequesters its CO2 is given a reduction of about 25 points off its
per-gallon carbon intensity (CI). However, a plant that
Carbon Sink LLC 1521 N Greenbrier St, Arlington VA 22205 (800)
583-5223

 captures its CO2 and uses it to make a product that is not sold
into the California renewable fuels market receives no reduction in
their CI, even though that CO2 is displacing fossil fuel use. If it
is used in making building materials or other long-lived products
it is not only displacing carbon from coal, crude oil or nature
gas, but is also sequestered in those products, making carbon
utilization even more beneficial to the climate than
sequestration.
If CARB grants equal treatment to carbon utilization and
sequestration it will spur innovative solutions for converting CO2
into low-carbon fuels and materials and allow biofuels plants that
do not have geologic sequestration options to contribute to the
solution.
Under the Carbon Sink model, we will produce zero-carbon eMethanol
from the CO2 emitted from the fermentation process at ethanol
plants in the US Midwest. Wind energy will be used to make green
hydrogen and to combine the CO2 and H2 to make eMethanol. The
eMethanol will likely be sold as a replacement for heavily
pollution shipping fuel (No. 6 fuel oil, or bunker fuel) to
shipping companies that are utilizing ships that are
duel-fuel/methanol compatible, which is a growing number in the
global fleet. Because of existing market forces, several global
shipping companies are converting their fleet to methanol
compatible ships to decarbonize their operations and, in turn, help
their customers cut the carbon footprint of their supply chains.
Fortunately, many consumer brand companies are responding to
customer pressure to cut emissions, and this is translating to
shipping companies taking material steps to compete in the low-
carbon transportation market, including paying a premium for
low-carbon fuels and signing long-term contracts.
In California, methanol is not a qualified blend-stock with
gasoline but could be utilized in certain applications such has
harbor operations like ferries, tugs, loading and warehouse
vehicles, rail, power generation and potentially some fleet
vehicles. Currently, these markets do not exist and growing them
will be difficult due to the "chicken and egg" nature of the
problem: does someone invest in capital equipment that runs on
eMethanol before there is sufficient production of eMethanol? We
believe that, because of the increasing availability of
methanol-powered fuel cells, there will be growing options for
carbon-neutral ferries and harbor vehicles, trains, and trucks in
the coming years. Until then we will likely focus on decarbonizing
the shipping industry and companies like Maersk, Stena, MSC,
Oldendorff and others who are actively seeking eMethanol supplies
as the primary substitute for petroleum-derived fuels.
If CARB does not change its current policy, favoring carbon capture
and sequestration over carbon capture and use, producers of
carbon-based products will be hampered by
Carbon Sink LLC 1521 N Greenbrier St, Arlington VA 22205 (800)
583-5223

 the availability of CO2. Accordingly, a change in the policy to
provide CI score credits to ethanol plant owners for both
sequestration and carbon capture and use will support the creation
of a US production ecosystem whereby the CO2 our economy needs for
our modern lives is increasingly from the atmosphere rather than
from underground.
Sincerely,
James P McVaney
Chief Commercial Officer, Head of Communications Carbon Sink LLC
(800) 583-5223
JIM@CarbonSinkLLC.com
www. CarbonSinkLLC.com
Carbon Sink LLC 1521 N Greenbrier St, Arlington VA 22205 (800)
583-5223

Attachment: www.arb.ca.gov/lists/com-attach/19-sp22-slcp-ws-AGNQNwd0BzYCa1Q6.pdf

Original File Name: Carbon Sink comments to CARB 20210922.pdf

Date and Time Comment Was Submitted: 2021-09-22 15:35:24



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