Comment Log Display

Darling International Inc. ("Darling")is commenting on two
pathways released by the California Air Resources Board
("CARB")in its July 20, 2009 announcement.Specifically, Darling
offers comments on the pathways for (1) convering used cooking oil
(UCO) to biodiesel and (2) tallow to renwable diesel.

Darling encourages CARB to consider a broader survey of rendering
industry data for natural gas and electricity used to produce
Tallow and UCO too.  This may help to address concerns that the UCO
pathway and the Tallow pathway relied on very different sources to
obtain data on the energy used for processing UCO and rendering
animal by-products.  More consistency in the approach used in each
of these pathways is appropriate because the same renderers
frequently use the same site for both processes: processing UCO and
rendering of animal by-products.

Darling also encourages CARB to complete the following regarding
these and subsequent pathways:

1.	Develop a pathway for making biodiesel from Tallow (produced in
California) as soon as is practicable.  

2.	Address our concerns with using co-processing of Tallow with
crude oil for its Tallow to renewable diesel pathway.  Darling
recommends using a dedicated hydro-treating facility that produces
a pure renewable diesel that is suitable for use neat or for
blending with petroleum diesel.


3.	Remove the transportation of Tallow from the Midwest to make
renewable diesel and modify the Tallow to renewable diesel pathway
to apply to Tallow produced in California.

4.	Develop a pathway using UCO as a feedstock for renewable diesel
in a dedicated facility similar to the one recommended for Tallow. 


5.	Consider methodology that can be applied to determining the
carbon intensity of blended feedstocks consisting of various
proportions of UCO and Tallow when such blends are used as
feedstock for either biodiesel or renewable diesel.

These and other comments are detailed in the attached file.