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Dear CARB personnel,

I appreciate the opportunity for California citizens such as myself
to express our opinions regarding the LCFS program. The current and
proposed growth in biomass-based diesel production in the United
States will continue to have large effects on the feedstock markets
used to produce the fuel. Federal and/or state legislation that
would make sustainable aviation fuel economically viable will only
add to the feedstock pressure. Additional greenhouse gas emissions
from the transportation of feedstock and finished products are
accounted for in GREET modeling, but given their relatively small
contribution to the overall CI score, have incentivized transport
of domestic feedstock to foreign refineries, which in turn
transport the refined product back to the United States, largely
California. Although within the letter of the law, this does
somewhat go against the spirit of the law. Of course, petroleum
markets are international as well, and subject to the same
arbitrage calculations that lead to long crude oil and refined
product voyages, so it is hard to pick on the liquid biofuel
markets for this same behavior. It is unfortunate there was no way
to fairly incorporate a "closer to home" factor in LCFS
calculations to try and reduce the GHG emissions involved in
transport of feedstock and refined product. A Federal LCFS-like
program would likely allay this to some degree, but for the time
being California will be the main product market. Again, thank you
for the opportunity to comment. 

Sincerely,
Josh Kehoe

Original File Name:

Date and Time Comment Was Submitted: 2022-01-07 16:15:44