August 8, 2022
Liane M. Randolph
Chair California Air Resources
Board
1001 I Street Sacramento, CA
95814
RE: Comments on the Draft 2022
Climate Change Scoping Plan Update
Dear Chair Randolph and Members of
the California Air Resources Board (CARB):
Global Clean
Energy is a California-based renewable fuels innovator producing
ultra-low carbon renewable fuels from patented nonfood camelina
varieties. Thank you for the opportunity to comment on the 2022
Draft Climate Change Scooping Plan Update.
Global Clean Energy is committed to
advancing climate reduction targets to improve air quality
throughout the Golden State. We support CARB’s proposal to
accelerate carbon reduction targets 30 percent by 2030.
Given the push to fully decarbonize California
by 2045 (EO B5518) we see heightened reduction as beneficial to
achieving these goals, while recognizing that renewable fuels can
play a pivotal role in meeting these targets. We appreciate CARB
taking biofuels’ unique attributes into account when crafting
this updated scoping plan.
One of the fuels
we create, renewable diesel, is especially helpful in achieving the
state’s decarbonization goals. Renewable diesel significantly
reduces criteria pollution, including NOx and PM, as well as
reducing GHG emissions by up to 85% (depending on feedstock). In
fact, according to CARB’s Renewable Diesel Workshop¹,
using renewable diesel on all tier 0-4i equipment in the San
Joaquin Valley (2025) would reduce NOx emissions by 0.55 tpd and
PM2.5 emissions by 0.073 tpd. Renewable Diesel has fewer GHG and
local emissions than both traditional diesel and biodiesel fuels,
acts as a drop-in replacement for modern traditional diesel engines
with no blending required, and unlike ZEVs, does not require
largescale infrastructure replacement. In addition, renewable
diesel is readily available across the majority of California and
is at cost parity with CARB ULSD.
In addition to producing renewable
diesel, we also produce renewable propane, naphtha, and butane.
These renewable byproducts can then be used to
support further reduction of GHG and other emissions in
California. For example, renewable propane from camelina for
school buses, forklifts, and other equipment would have the same
low CI as renewable diesel and would produce lower NOx and PM than
traditional diesel or gasoline. Renewable naphtha and butane
also help lower the GHGs and production costs associated with
gasoline as they are used as a gasoline blendstock.
We understand from public workshops
that CARB is seeking input on reducing lipid-based feedstocks for
renewable fuels so as to not advance food vs. fuel concerns or
cause indirect land use change. We would urge CARB to consider an
exemption for certain lipid-based feedstocks certified as low
ILUC-risk, similar to the European Union’s
RED II directive.
Global Clean Energy’s primary
renewable fuel feedstock, our patented camelina, is a lipid-based
feedstock that is nonfood, grows between traditional crop cycles on
dryland farms, and does not contribute to land use change. Further,
camelina has the potential to be the lowest carbon renewable fuel
feedstock on the market.
Camelina-based renewable fuels
produced by Global Clean Energy have an ultra-low carbon intensity
(CI) score that has the potential to go below zero. We were issued
a first-of-its-kind LCFS pathway by CARB in 2015. For reference,
camelina is an oilseed crop, member of the mustard seed family and
a distant relative of the canola plant.
Global Clean Energy’s camelina
is grown domestically and contributes to rural economic development
by providing farmers additive income on land otherwise left idle.
Further, our company’s vertically integrated structure allows
us to drive down our lifecycle carbon emissions. Through
streamlined operations and identifying efficiencies, we expect to
reduce our carbon emissions to single digits or below in coming
years.
Our Bakersfield Renewable Fuels
Refinery, which is anticipated to begin production later this year,
is actively contributing to the “Just Transition” from
fossil fuels to clean energy careers and has a nameplate capacity
of 15,000 barrels per day or over 200 million gallons per year. Our
fuels will be readily available to the California market through
existing distribution agreements, and we expect the Jan Juaquin
Valley’s agricultural and trucking sectors to consume much of
what we produce.
Given camelina-based fuels’
positive traits, we encourage CARB to exempt it from any
lipid-based feedstock restrictions. Enacting these changes will ensure our company and others
can continue to produce renewable fuels in California that further
the domestic clean energy supply, lower carbon emissions, and
strengthen our state’s clean energy economy.
Further, as CARB
seeks to implement the goals of EO N7920, we encourage you to
prioritize the use of renewable diesel in medium and heavy-duty
vehicles. There are no technical, supply, or financial reasons why
medium and heavy-duty vehicles cannot switch to renewable diesel
use rather than ZEVs to support CARB’s carbon reduction
objectives. By encouraging renewable fuels’ heightened use in
these applications, CARB can help to ensure limited economic
impacts on businesses that would otherwise have to replace their
existing vehicle fleets while achieving environmental
objectives.
Renewable diesel
can also be used as a fuel source for rail, agricultural equipment,
commercial harbor craft, and airport ground support equipment as
well as aviation fuel – other stated carbon reduction targets
of your agency – all of which are fuel options our company is
exploring at our Bakersfield site.
We appreciate CARB
taking the benefits of renewable fuels produced using camelina into
account in its rule making process and encourage you to consider
enacting the above-mentioned low ILUC lipid-based feedstock
exemptions to further advance California’s emissions
reduction targets.
Sincerely,
Amanda Parsons DeRosier
Vice President of Investor Relations
and Public Affairs
Global Clean Energy | www.GCEholidngs.com
Amanda.DeRosier@GCEholdings.com
562-233-5146
https://ww2.arb.ca.gov/sites/default/files/2021-09/ORD_Amendment_Workgroup-Renewable_Diesel.pdf