Comment Log Display

February 20, 2024

Clerk of the Board
California Air Resources Board
1001 I Street
Sacramento, CA 95814


Dear Chair Randolph and Honorable Members of the Board, 

Thank you for your continued dedication to enhancing air quality in
the Golden State through the proposed updates to the Low Carbon
Fuel Standard Program (LCFS). We commend your decision to further
encourage and not restrict the use of crop-based feedstocks within
the proposed LCFS amendments under consideration. 

The proposed accounting requirement for crop-based feedstocks, to
trace their origin and undergo independent certification, aligns
with the California Air Resources Board's commitment to ensuring
crop-based feedstocks do not contribute to adverse impacts
associated with land use change or limiting food supply. This
proactive approach addresses concerns raised by the Environmental
Justice Advisory Committee (EJAC) regarding "expanse of global
deforestation, unsustainable land conversion, or adverse food
supply impacts."

Our company, Global Clean Energy, stands ready to assist CARB in
achieving this important goal. As a California-based renewable fuel
innovator with offices in Torrance and a renewable fuels production
facility in Bakersfield, we work tirelessly to ensure renewable
fuels that we produce can have the lowest possible carbon
intensity. What sets us apart is our focus on producing ultra-low
carbon renewable fuels using Camelina sativa (camelina), a crop
that alleviates the foregoing concerns.

Unlike other renewable fuel feedstocks, camelina is nonfood.
Camelina is quick to mature, is tolerant to drought, promotes
biodiversity, sequesters carbon as it is grown, and provides soil
health benefits similar to those of cover crops. Importantly,
camelina does not displace food crops when grown. Instead, it grows
on existing farmland during the fallow between crop cycles -
providing a new revenue source to farmers and rural agricultural
communities while also strengthening our domestic energy supply.
With these unique traits, camelina has the potential to be the
lowest carbon intense renewable fuel feedstock on the market. 

Labeled as an "Intermediate Crop," camelina falls under a new
classification of biofuel and renewable fuel feedstocks.
"Intermediate Crops" act as harvestable cover crops that can reach
maturity during an idle or fallow period on existing farmland,
which does not cause land use change or adversely impact food
supply. Intermediate crops like camelina can help California and
our nation reach our renewable fuel and SAF goals responsibly
through biomass.

As you endeavor to create an accounting mechanism to track
feedstocks to their point of origin and develop the independent
feedstock certification process recommended within your proposed
LCFS rule, we encourage you not to recognize the importance of
emerging crops like camelina. By incentivizing the further adoption
of "Intermediate Crops" like camelina among growers and renewable
fuel producers, we can help ensure land use change is prevented,
soil health is protected, and renewable fuel feedstock demand can
be met responsibly. 

As new crops, education and incentives are vital to ensure
"Intermediate Crops'" continued adoption and future success.
Recognizing that newer feedstocks lack the resources of traditional
commodities like soy or corn, we recommend that accounting rules
should not place "Intermediate Crops" like camelina at a financial
disadvantage as they establish themselves within the market.  

As experts in this emerging field of "Intermediate Crops" we stand
ready to work with CARB staff and others to lend data and provide
guidance in the development of an accounting mechanism addressing
GHG and air pollution emissions associated with feedstock
production pathways.

We look forward to working together to ensure Intermediate Crops
are supported while these accounting criteria are developed. Thank
you for taking the time to consider our comments. 

Sincerely, 


Amanda Parsons DeRosier
Vice President of Public Affairs and Investor Relations
Global Clean Energy   www.GCEholdings.com