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Comment #3 for Public Workshop to Discuss Potential Changes to the Low Carbon Fuel Standard
(lcfs-wkshp-feb23-ws) - 1st Workshop

First Name: Daisy
Last Name: Laurino
Email Address: daisy.laurino@dot.ca.gov
AffiliationCaltrans
SubjectLCFS Workshop - alternative sources of biomass and methane
Comment
Hi -
Comment in response to slide 41.

Slide 39 states an increase of soybean production from 35 to 98
million acres in 2025 and this will increase going forward to
achieve goals. These increases in farmland will also increase GHG
emissions and need for water.
Slide 11 shows a fast increase of renewable diesel volumes, plus
existing alternative fuels using biomass.

Due to the amendment to Order 2449 requiring renewable diesel for
prime contractors, Caltrans studied producers of renewable diesel
and observed that feedstock prices affects decision to produce.
https://www.reuters.com/business/energy/cvr-pauses-renewable-diesel-plans-feedstock-prices-surge-2021-08-03/

Therefore, 3 concerns - increase of water requirements in a drought
ridden CA, consumers facing higher food prices and producers
affected by high feedstock prices. Slide 41 - reflects these are
also CARB's concerns.

What about CARB connecting LCFS' program with recycling instead?
•	Instead of virgin biomass, how about recycled biomass from
restaurants, schools, etc. example Crimson Renewable Energy  
https://www.turnto23.com/news/local-news/crimson-renewable-energy-opens-new-facility-in-southwest-bakersfield
•	Find an alternative source for methane like CALRecycle or
disposal sites for plastics as source of CH4? or other wastes?

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Date and Time Comment Was Submitted: 2023-02-22 14:16:55


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