Comment Log Display

October 6, 2009 
Chairwoman Mary Nichols California Air Resources Board 
1001 I Street Sacramento, California 95814 
Re: "Proposed Regulation to Implement the LCFS" (Staff Report.
Volume I, March 5. 2005) (the "Report") 

Cobalt Technologies, Inc., based in Mountain View, California, is
a private company that is leading the commercialization of
biobutanol. We commend the Air Resources Board for adopting the Low
Carbon Fuel Standard last April and taking on the many challenging
issues surrounding the goal of reducing the carbon emissions of
liquid transportation fuels. 

Cobalt has developed innovative technology for the production of
biobutanol from non-food, lignocellulosic material. Our process
reduces lifecycle greenhouse gas emissions by more than 85%
compared to gasoline. Our facilities combine low-cost feedstock 
pretreatment, a novel bioreactor design for high productivity
fermentation and a high degree of energy integration, which, taken
together, produce biobutanol at a cost that 
would be profitable at today's oil prices. 

Our process is based on the use of non-food feedstock, initially
woody biomass (consisting principally of thinning, mill residues
and sustainable roundwood), to be followed by agricultural residue
and dedicated low-input, high biomass energy crops. An important
differentiating attribute of Cobalt's process is the ability of
Clostridium to convert both hemicellulose-derived sugars and
cellulose-derived sugars, while most ethanol fermentations are
limited to conversion of monomeric glucose derived from hydrolysed
cellulose. In addition, the lignin portion of the biomass is burned
to provide energy for the production process, with excess renewable
electricity exported to the grid. 

Biobutanol is a high quality fuel and fuel blending component. As
noted in the Report, biobutanol can be blended with both gasoline
and ethanol. In addition, the Report notes that biobutanol has "a
number of advantages over ethanol," including higher energy 
density, less corrosivity, less volatility, compatibility with the
pipeline distribution system and the ability to be mixed in more
flexible proportions.
 
The Report asserts that "the technology [for producing biobutanol]
will not be fully commercialized until sometime after 2020." We
believe that we are on track to produce commercial quantities of
butanol by 2015 -in other words, on the same timetable, if not
sooner, than the large scale commercialization of cellulosic
ethanol. We are currently in the process of scaling up our
technology. We operate a pilot-scale fermentation system in
Mountain View and a pilot pretreatment facility in Colorado. We are
planning to build an integrated pilot facility during 2010 and
complete our first commercial-scale plant in 2013. We are currently
selecting sites for this plant, and among the most attractive
candidates are sites in several counties in northern California
with high availability of woody biomass (specifics have been
omitted for trade secret purposes). Once this facility is
operational, our ability to develop multiple commercial-scale
facilities simultaneously, and to license the technology to
independent project developers, would be limited only by the
availability of capital.
 
We understand that prior to selling biobutanol blends in
California a multimedia evaluation will be required, which can be
both expensive and time-consuming. It is our understanding that
another potential producer of biobutanol has already initiated such
an evaluation, and as test quantities of our biobutanol become
available we would expect to work closely with ARB (and, to the
extent feasible, with other producers) to ensure that all
applicable requirements are met. 

In addition, we understand that to be officially accorded a
carbon-footprint reduction for the LCFS, Cobalt's fuel will be
subjected to the California-Modified GREET Pathway for
Transportation Fuels. We have completed our own life cycle
analysis, based on GREET but supplemented by specific analysis of
our process where GREET data are lacking or inapplicable, and would
be pleased to share this analysis with the ARB staff. We are aware
of the Argonne National Lab corn-to-butanol GREET analysis;
however, the differences conferred by the two processes indicated
to us that we should generate our own pathway model. 
We also understand that one of the most challenging components in
developing fuel pathways is the assessment of indirect land use
changes (ILUC), particularly in relation to the use of food-based
feedstock. One of the advantages of using locally-sourced woody
biomass as a feedstock is that ILUC are only a minor factor under
almost any methodology. We are well aware of the controversy
surrounding the methodology for calculating ILUC and agree with the
ARB's approach of establishing an Expert Workgroup to assist the
Board in refining and improving the methodology for analyzing land
use and indirect effects from the production of transportation
fuels. 

We look forward to engaging with ARB staff as we move toward the
development of a fuel pathway for biobutanol from lignocellulosic
feedstocks. We are confident that Cobalt's proprietary technologies
will make possible a new generation of cost-effective and
domestically-produced biofuels that will play a significant role in
achieving the Low Carbon Fuel Standard and help maintain California
as the hub of green technology innovation. 

Sincerely,

Rick Wilson, CEO
Cobalt Biofuels

1 The Report also states that "staff is not aware of any facility
producing biobutanol on a commercial basis." While this is true in
the United States, commercial facilities for the production of
biobutanol, based on the ABE fermentation method, from foodstocks,
are in intermittent operation in Russia and China, depending on
market prices.