Comment Log Display

As with the sorghum issue, Calgren Renewable Fuels applauds the ARB
for its handling of the re-authorization of the LCFS. Perhaps the
re-authorization was prompted by the lawsuit brought by others in
the ethanol industry. If so, we applaud the ARB for its measured
and appropriate response. While Calgren did not and does not
support the lawsuit, it does support the ARB's attempts to
strengthen the LCFS.

To be stronger, the LCFS must be based upon good science.
Calculation of life-cycle carbon intensities is inherently
complicated and a few anomalies are to be expected. We believe our
consultant has discovered one such anomaly regarding the CI impact
of denaturant. Please review his comments as reflected in the
attached summary. Correcting what appear to be inconsistencies and
errors regarding the CI impact of denaturant on fuel ethanol will
help strengthen the LCFS.

On a somewhat related subject, we applaud the ARB for correcting
the erroneous 1:1 distillers grain-to-corn displacement ratio that
appears in GREET 1.8. But we firmly believe and have previously
submitted data showing that the displacement ratio varies somewhat
depending upon whether distillers grain is fed to hogs, poultry,
feedlot cattle or dairy cows. We urge the ARB to take note of
relevant research in this area and apply it where applicable.

Thank you for the opportunity to comment.