Comment Log Display

Dear Chair Randolph and Members of the Board,

Thank you for the opportunity to comment on the proposed
modifications.  New Leaf Biofuel operates a small biodiesel
refinery in San Diego utilizing recycled cooking oil feedstock. We
are members of California Advanced Biofuels Alliance and the
National Biodiesel Board, and we second the comments submitted
jointly by those organizations regarding these proposed amendments.
 New Leaf is very concerned that staff has not addressed the
concerns brought up at the April 2020 hearing, specifically
regarding the very complicated and costly certification procedures
for additive companies.  

The additive company that New Leaf is currently using to comply
with ADF has indicated that these procedures are too costly and
will require them to leave this industry should they be adopted. 
The other additives on the market are either too costly or too
dangerous, and are therefor unworkable.  As we have explained to
staff numerous times, Renewable Diesel is not available to small
companies to meet the compliance obligations either.  (A mass
balance approach would be a much more workable option).  Finally,
we are very confused by the new 2% NOx reduction requirement that
was not part of the original rulemaking, nor discussed with the
stakeholders.  

The regulation, as it currently stands, is likely to be a final
nail in the coffin for the small biodiesel producers, even with the
regulation not being enforced until August.  We pride ourselves
with having a very good working relationship with CARB regulators. 
We look forward to continuing this discussion in a way that allows
biodiesel to continue to provide the carbon reduction benefits to
the State of CA.  

Kind Regards,

Jennifer Case
President 
New Leaf Biofuel