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Esteemed Chair, members of the board, members of the EJAC,

My name is Gary Hughes, I work with the international organization
Biofuelwatch, I want to express congratulations to the EJAC and
CARB for a well organized informative meeting. Some excellent
presentations, thank you. These comments were meant to be provided
as oral public comment during the meeting but for efficiency and
for saving time AND out of respect for meeting participants, these
comments are offered in written form. 

Our organization stands by the recommendations of the EJAC, such as
the recommendation to cap lipid feedstocks for making fuels like
renewable diesel. We think history will look unkindly on the
promoters of the scaling up the production and utilization of
liquid biofuels. Among other concerns, the deforestation risks are
immense and remain inadequately addressed by CARB. A cap on these
lipid feedstocks is a good first step, phasing out these lipid
feedstocks altogether would be a better overall objective. The same
as many meeting participants who offered presentations today we at
Biofuelwatch also have some serious doubts about the accuracy of
the estimation by CARB of the GHG impacts resulting from the
manufacture and utilization of these liquid biofuels.

Along those lines I want to address some misleading information
about renewable diesel that was offered by CARB staff when
describing the LCFS.

There was a characterization of 'biomass based diesel' as being a
'non fossil fuel', but that ignores the realities of the
hydrotreated vegetable oil (HVO) refining process, which is fossil
fuel intensive, as making renewable diesel or sustainable aviation
fuel from feedstocks like soy or animal tallow relies on emissions
intensive fossil gas for the refining process. The steam
reformation of fossil gas (steam methane reforming-SMR) is the
singular current source of the hydrogen that is required in massive
amounts to make a liquid fuel from lipid feedstocks like vegetable
oils (which most of the world refers to as food).

At the same time we know that some of the feedstocks being utilized
to make so called renewable diesel are also petroleum based, an
example being the highly publicized efforts of a company called
Fulcrum Bioenergy to process plastic garbage (municipal solid
waste) into a 'syn crude' feedstock to use at the Marathon/Neste
joint venture biofuel refinery in Martinez. Though there are real
reasons to have doubts about whether these 'syn crude' feedstocks
are being produced and utilized in significant amounts, because the
promise of Fulcrum Bioenergy is a bit of a 'waste to energy'
unicorn, it goes with out saying that these are not benign
feedstocks, waste to energy was long ago debunked as a climate
solution, and the refining process to make liquid fuel from such a
feedstock is still heavily reliant on fossil energy.

So, after all that has happened over the last years, with the
overall irregular governance in the Bay Area refinery corridor, and
with what a court has now ruled was a totally flawed California
Environmental Quality Act review of the refinery conversions to
liquid biofuels, it remains truly worrisome that CARB staff
continue to infer that these high carbon liquid biofuels are free
of fossil fuel, when the truth is far different.

But this obfuscation also distracts from another very real issue,
and that is the public safety issues at the refineries making these
fuels, as the reliance on tremendous amounts of hydrogen to
hydrotreat lipid feedstocks is indeed raising the risk of high
temperature hydrogen imbalances in the refining process, which
results in upsets, extensive flaring and increased risk of
explosions. Nothing was shared today about the problems around the
biofuel refinery conversions themselves, and the emerging public
safety and public health concerns. 

Unfortunately, we have seen that CARB trends towards a sweep it
under the rug approach when it comes to addressing the real world
impacts of these biofuels.

It is long past time for decision makers to stop taking refuge in
the political convenience of converting fossil fuel energy
infrastructure to bioenergy infrastructure and calling it a climate
solution, because the outcomes are not as safe, green or as climate
friendly as we are being told, and precious time is being wasted.

Our organization asks that there be greater scrutiny of these
refinery conversion dynamics in the future. 

Thanks for your attention to this comment. Great meeting tonight.

Gary Graham Hughes
Americas Program Coordinator
Biofuelwatch