Comment Log Display

Staff,
I am writing to support the position of the California Biodiesel
Alliance, which is to urge adoption of the Low Carbon Fuel Standard
with an accelerated implementation schedule for the diesel fuel
pool that more aggressively decreases carbon intensity beginning in
2010. California's biodiesel industry, which produces the majority
of its fuel from waste sources, can be a model for practices that
lower green house gases dramatically and should be given every
opportunity to succeed. 

California’s 2009 biodiesel production capacity is more than
capable of meeting the demands of a 1% reduction in carbon
intensity beginning in January 2010.  A 1% reduction could be
achieved with 31 to 35 mgpy of California produced biodiesel made
from waste feedstocks such as animal fats and used cooking oils
(the latter is based on an LCFS pathway for biodiesel produced in
California using inedible animal fats and used cooking oils
achieving a 70% and 80% reduction respectively in carbon intensity
versus the current petroleum diesel baseline of 94.71 gCO2e/MJ).


I also write to urge ARB to develop and publish LCFS fuel pathways
for biodiesel produced in California and for biodiesel using waste
feedstocks such as used cooking oil and inedible animal fats. Thank
you for your consideration.

Eric Smith, Director
Green Depot San Francisco