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We kindly request consideration of adding to CCR Section
95489(c)(1)(A), Chemistry Replace Steam, as an innovative
production method.  This will incentive crude producers to stop
using steam to extract heavy oil, reducing emissions in
California's most disadvantaged communities while reducing overall
fossil fuel demand.    

Approving this incentive could reduce oil extraction emissions
millions tons of CO2e, eliminating 1 billion mcf of natural gas
burned by 2035.  Reducing the dirtiest oil's carbon intensity over
60%. California producers will deliver the cleanest crude to
California refineries, reducing emissions, imports, costly
refinery
upgrades all while supporting a cleaner transition.  

The chemistry proposed is plant based, pH neutral and
biodegradable.  This is safer, cleaner and more expensive than
steam.  Which is why approval of this innovation is necessary to
accomplish the mission of CCR Section 95489.  All approved
innovations in 95489(c)(1)(A) are aimed at reducing, replacing or
eliminating burning natural gas, either for steam or electricity. 
Approved innovations are reducing around 55,000 tons CO2e per
year.
 Approving this innovation reduce millions of tons within the
first
two years.  

This chemistry has so many other applications than just oil and
gas.  The biggest opportunities in O&G are the dirtiest production
methods, which is steam in California and Canada.  Next would be
heavier oils from Alaska North Slope.  

This chemistry outside O&G is an all-natural firefighting
suppression innovation, lower emissions in agriculture, water
treatment, enhanced oil recovery, eliminating solvents and harmful
cleaning products, soil remediation, and the opportunities keep
growing.  

Attached is how chemistry replaces steam, and an application for
approval.  The chemistry proposed is plant based, pH neutral and
biodegradable, that is 13x lower carbon intensity than steaming.  


Thank you for your consideration for creating California's clean
transition.