Submission Number: 623
Submission ID: 8911
Submission UUID: a2419f9e-0231-409c-bc98-724490d7c8c7

Created: Mon, 03/04/2024 - 22:10
Completed: Mon, 03/04/2024 - 22:10
Changed: Tue, 03/05/2024 - 10:43

Remote IP address:
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes

Submitted Comment
Joshua Kehoe
Application No. B0440

Thank you to CARB for providing this forum for public comments. Thank you to Phillips 66 for submitting this Tier 2 application.

My comment here is that I trust non-US/EU sourced "UCO" as far as I could throw a barrel (42 gallons) of it. While I understand there are attempted safeguards to assure that UCO feedstock in indeed what it purports to be, there is so much potential for misrepresentation of said feedstock that I hope CARB requires very strict verification of such feedstock from Asian sources. My concerns revolve around palm oil, of course. I strongly oppose any palm oil-derived biofuels given the deforestation inherent in palm oil plantations. I may come off as cynical, but I also oppose Asian "used cooking oil/UCO" because the temptation to launder virgin palm oil is too strong. Carbon intensity (CI) scores are so critical in assigning value to the resultant fuel (LCFS scores, 45Z scores come 2025, etc), and true "waste" feedstocks assigned an ILUC value of "0" are limited enough that attempts at cheating the system have to be assumed to be the baseline state. To be blunt, I would rather have US-sourced, soybean oil-based biofuels than any Asian-sourced "UCO"-based biofuel. The robustness of the audit chain for the former I will trust. The audit chain for the latter....not so much.

As a California resident exposed to the added costs of LCFS and CA cap-and-trade, I very much wish that any additional costs I pay for my transportation fuel be reflected in a real-world reduction carbon intensity of such fuels. I have no issue with paying more for lower-CI fuels. While I am sure Phillips will have ample rebuttal regarding the robustness of the audit chain for their UCO feedstock sourced from Asia, the fact remains that I as a California consumer do not have such faith in the veracity of said feedstock. I consider myself more well versed than the average resident in this regard, but also recognize there is a great deal of information I am not privy to. If Phillips 66 wishes to use UCO as a biofuel feedstock, I am all for it. I ask that they source it from the US or Canada though. Too much potential for fraud otherwise.

Josh Kehoe MD