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Comment 70 for Public Comments for LCFS pathway applications (tier2lcfspathways-ws) - 2nd Workshop.
First Name: Patrick
Last Name: Harrington
Email Address: pharrington@crowniron.com
Affiliation: Crown Iron Works
Subject: B017901: Tier 2 pathway for Renewable Diesel (RND) from Distillers' Corn Oil
Comment:
Hello, This is in reference to B017901: Tier 2 pathway for Renewable Diesel (RND) from Distillers' Corn Oil (003) Fuel Producer: Neste Singapore Pte Ltd (4137) It seems that exporting Distillers' Corn Oil (and other fats/oils) from North America across the ocean to Singapore, only to ship it back across the ocean to California for LCFS credits goes against the heart of reducing carbon footprint. A simple gut check While the carbon intensity score may reflect the additional ocean freight and still prove economical for Neste, it seems there should be a greater CI score penalty for such significant transport distances. Not only for the substantial ocean freight, but also considering the additional truck/rail transport by the aggregator of Distiller's Corn Oil from the Midwest to the Coast. Thanks, Patrick Harrington
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Date and Time Comment Was Submitted: 2021-06-11 06:51:35
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