Submission Number: 956
Submission ID: 12541
Submission UUID: da7612af-b74e-4e55-9730-26d173cc1c2f

Created: Fri, 05/31/2024 - 14:02
Completed: Fri, 05/31/2024 - 14:02
Changed: Fri, 05/31/2024 - 14:06

Remote IP address: 162.237.78.97
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes
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Submitted Comment
Dave Rhody
Climate Reality Leader
Comments on application no. B05030

Distilled corn oil (DCO) is wrongly categorized as a waste oil. It is not.

DCO is commonly used as a supplement for cattle and pet food. When CARB uses it for biofuels, the cattle and pet food industry usually turns to palm oil imports as a replacement. They source the palm oil from places like the Amazon rainforest where jungle is cleared to grow the palm oil.

Furthermore, biofuels are not a clean energy solution. The GHG emissions from planting, fertilizing, harvesting, transporting and refinish biofuels are greater than the emissions from petroleum.

Most of the feedstocks used in CA biofuels are food crops (including DCO). CARB's LCFS incentives are creating land use changes that are interfering with global food supply.

Distilled corn oil (DCO) is wrongly categorized as a waste oil. It is not.

DCO is commonly used as a supplement for cattle and pet food. When CARB uses it for biofuels, the cattle and pet food industry usually turns to palm oil imports as a replacement. They source the palm oil from places like the Amazon rainforest where jungle is cleared to grow the palm oil.

Furthermore, biofuels are not a clean energy solution. The GHG emissions from planting, fertilizing, harvesting, transporting and refinish biofuels are greater than the emissions from petroleum.

Most of the feedstocks used in CA biofuels are food crops (including DCO). CARB's LCFS incentives are creating land use changes that are interfering with global food supply.
Distilled corn oil (DCO) is wrongly categorized as a waste oil. It is not.

DCO is commonly used as a supplement for cattle and pet food. When CARB uses it for biofuels, the cattle and pet food industry usually turns to palm oil imports as a replacement. They source the palm oil from places like the Amazon rainforest where jungle is cleared to grow the palm oil.

Furthermore, biofuels are not a clean energy solution. The GHG emissions from planting, fertilizing, harvesting, transporting and refinish biofuels are greater than the emissions from petroleum.

And you have a problem with fraud in the one feedstock that is not a food crop, used cooking oils (UCOs), as reported by the International Council on Clean Transportation (ICCT). See attached.