| First Name: | Devin |
|---|---|
| Last Name: | Mogler |
| Email Address: | devin.mogler@gpreinc.com |
| Affiliation | Green Plains Inc. |
| Subject | RE: LCFS Workshop Issue- CI of Distillers Corn Oil |
| Comment |
The proposed changes in carbon intensity (CI) for distillers corn oil (DCO) as a feedstock for advanced biofuels is inconsistent with science and with CARB's track record, and this increase from 100 g CO2e/lb oil to 225 g CO2e/lb oil should not be adopted. This apparently arbitrary increase in the CI of DCO - a waste oil from the ethanol production process that in unfit for human consumption - would make its CI higher than that of soybean oil, which is 233 g CO2e/lb oil. Ethanol producers continue to find new ways to extract more DCO from the production process without negatively impacting the feed quality of the distillers grains, and the domestic industry captures over 5.5 billion lbs of DCO each year. Unfairly penalizing this inedible oil would slow or halt investments in technology that is being rapidly deployed across the ethanol industry to capture more DCO to serve as a low carbon feedstock for the production of advanced biofuels. Originally, CARB only ascribed 4 g CO2e/lb oil to DCO, and the current 100 g CO2e/lb oil is higher than Argonne GREET's 39 g CO2e/lb oil, so one could argue the CI is already too high, and a further increase seems out of line with the latest modeling. We strongly encourage CARB to reconsider this proposed increase, and to adopt the Argonne GREET value of 39 g CO2e/lb oil. In addition, it may be worthwhile to complete a full GTAP analysis before any further proposals to increase this CI value, and provide more visibility into the modeling behind future changes going forward. |
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Original File Name:
Date and Time Comment Was Submitted: 2023-05-31 17:23:00 |
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