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Dear Chairman:

Calgren Renewable Fuels is a California ethanol producer that
desires to use more grain sorghum as feed stock. Sorghum is
low-water and, we believe, will help us reduce the carbon intensity
of our fuel ethanol. We are in close touch with the National
Sorghum Producers (NSP) and understand they will also submit
comments.

While bemoaning the fact that others in the ethanol industry saw
the need to file suit against the ARB regarding the LCFS, we
applaud the ARB's reaction - re-authorizing the LCFS and working to
improve the accuracy of carbon intensity scores sends the right
message. 

As will the NSP, we thank the ARB for paying special attention to
sorghum iLUC, sorghum fertilizer requirements, and nitric oxide
emissions from sorghum stover. We would ask that the ARB be alert
for future information on sorghum root;shoot ratios and incorporate
it into future versions of CA-GREET.

Lyle Schlyer
President, Calgren Renewable Fuels