August 8, 2022
Low Carbon Fuels Standard Program
California Air Resources Board
Sacramento, CA 95814
Re: Yosemite Clean Comments on LCFS
Program Staff Presentation on July 7, 2022
To the LCFS Program:
The LCFS plays a critical role in the
transition to a zero emission transportation sector in California,
and biofuels from forest waste play a critical role in the LCFS.
CARB has an opportunity to either assist the state and federal
governments in their effort to reduce wildfire risk, or to hinder
them, based on the LCFS policies they adopt or abstain from
adopting as relates to forest biomass.
The Problem
While it goes without saying, California is in the
midst of a crisis of catastrophic proportions. As stated by the
U.S. Forest Service (“USFS”), “Wildfires have
been growing in size, duration, and destructivity over the past 20
years. Growing wildfire risk is due to accumulating fuels, a
warming climate, and expanding development in the wildland-urban
interface. The risk has reached crisis proportions in the West,
calling for decisive action to protect people and communities and
improve forest health and resilience. It will take a paradigm shift
in land management across jurisdictional boundaries to reduce risk
and restore fire-adapted landscapes.”[1]
In response to the crisis, USFS set a goal to treat 50
million acres over the next 10 years. CARB recently came out in its
draft scoping plan stating that the 1 million acre goal set by the
Newsom administration and the Forest Service is too small, and
California needs to be treating over 2 million acres per year. By
conservative estimates, this treatment will generate over 20
million tons of waste biomass per year, which as of now, California
has no market for.
The Solution
This waste, which is a biproduct of work essential to
saving our forests, could be transformed into carbon negative
transportation fuels, including hydrogen, if policy allows for it.
This biofuels pathway allows for significant Carbon Capture and
Sequestration, and is sited by Lawrence Livermore National
Laboratories as a critical component to getting California to
carbon neutral. Yosemite Clean Energy
(“Yosemite”) and companies like us have the technology
and business development solutions to turn California’s
forest wood waste into carbon negative biofuels while reducing the
risk of wildfire.
Yosemite is a bioenergy development company that
specializes in transforming farm and forest wood waste into carbon
negative green hydrogen and renewable natural gas, providing
renewable solutions to California’s transportation and
broader energy sectors while reducing risk of wildfire, raising air
quality, and creating jobs and economic stimulus in minority,
tribal, and other underserved communities. Yosemite is developing a
network of biofuels plants that are locally owned by the
agricultural and forest communities they serve. The company is at
various stages of development planning on biofuels plants across
the state of California, with operations at Yosemite’s first
plant scheduled for Quarter 1 of 2025. Yosemite’s standard
plants will utilize 90,000 bone dry tons of wood waste per year to
produce an estimated 13 metric tons of green hydrogen and 31 metric
tons of RNG per day.
Our Request to CARB
In its initial comments to CARB, Yosemite
has two recommendations, included below, followed by description of
each and why each was included. Yosemite foresees engaging with
CARB on numerous topics throughout the process, but wanted to get
on the record today to bring up these two key issues.
Yosemite recommends that:
1. Avoided emissions for
Forest Residuals. CARB should develop a robust model within the
LCFS to consider avoided emissions for fuels derived from forest
wood waste that would otherwise be burned or decompose. Emissions
from catastrophic wildfire single-handedly displace all particulate
and GHG emissions reductions the state is achieved to date.
Capturing avoided emissions in the LCFS will promote private sector
contribution to wildfire risk reduction and accurately reflect true
CI score of fuels from forest waste.
2. Sustainability criteria
for Forest Residuals. CARB should abstain from implementing
sustainability criteria for biofuels produced from forest wood
waste, just as it has done to date. Adopting sustainability
criteria such as that included in AB1122 would significantly
complicate woody biomass-to-biofuels projects, and hinder their
development. All biomass
removed from federal and state managed forests have obtained
permits and authorities under Cal Fire and USFS to remove the
biomass in question, and each additional government program
utilized implaments a unique set of requirements. CARB setting
additional standards within the LCFS will add one more layer of
complexity.
We look forward to additional engagement
with CARB on this topics, as well as others.
Sincerely,
Noah Jackson
Director of Strategic Operations
Yosemite Clean Energy
Noah.jackson@yosemiteclean.com
559-790-5155