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First, it is unclear from the application how the transport
distances for UCO are treated. What is not clear is if the oil is
purchased from aggregators, or if REG is collecting themselves.

If the aggregators are collecting the UCO, is the 50 mile default
and heavy duty truck assumption accurate?
If the aggregators are simply collecting UCO and delivering to the
facility and the pathway assumes a conservative extra 50 miles,
this should be made clear. 

If the transport distance is for collection only not purchased from
aggregators, are what does their transportation network look like?
Are they utilizing full 80,000 GVW trucks for collection, or
smaller trucks to pick up loads? If purchased by aggregators, the
oil collected by REG for processing would have been collected for
waste processing in any case.


Compare this to the recent pathway for General, which claims to
have records for transportation distances (given in miles given per
gallon), and gives a transportation of 5 miles. They specifically
call out obtaining the UCO directly from restaurants, rather than
aggregators.  

Secondly, the application assigns the US average electricity mix to
UCO rendering, which is defined in the feedstock phase.  However,
rendering is accomplished in the same location as biodiesel
production and rendering is the only activity that occurs in the
feed phase.  So, the region for feed and fuel should be the same.