Submitted Comment Name Gary Hughes Affiliation Biofuelwatch Subject B059904 - South American Tallow fuel pathway permit app no. B0599 Message To whom it may concern, On behalf of our organization Biofuelwatch I submit this rudimentary comment on the permit application no. B0599. In general the application fails to provide the necessary information to assess the accuracy or viability of the application. As an example, and in particular, the application includes fuel pathway B059904 (South American sourced Tallow transported by truck, rail and/or barge to Renewable Diesel plant in Saraland, AL). There is no way to verify or test in any way the fuel pathway app when an entire continent is listed as the source. It is absurd. This application ignores the complexity of these commodity supply chains. It is common knowledge that the livestock industry is one of the major drivers of land use change, including but not limited to deforestation, in South America. There are also intricate links between the livestock industry and the soy agroindustry sectors, both of which are drivers of forest degradation and forest loss. There is simply insufficient information provided in the application to even begin to assess the veracity or reliability of the details included in the application. For that reason we suggest that CARB reject the application, or at the very least reject the specific fuel pathway of B059904 that would source animal tallow from such an unspecific source as the entirety of the South American continent. Thank you for your attention to this comment. Gary Hughes Americas Program Coordinator Biofuelwatch File Upload (i.e., Attachments): N/A
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