Submission Number: 1476
Submission ID: 19356
Submission UUID: e7831eb0-ebdd-4a8b-b0f0-d9ffe8fcb880

Created: Thu, 12/05/2024 - 22:27
Completed: Thu, 12/05/2024 - 22:27
Changed: Fri, 12/06/2024 - 08:58

Remote IP address: 69.62.230.105
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
Joshua Kehoe
California resident
Application No. D0025

Dear CARB Personnel,

As always, thank you for this opportunity to comment on LCFS pathway applications that indirectly raise the price of fossil-based gasoline and diesel that all Californians are exposed to via passed-on compliance costs. I will be brief with my comments.

I have conceptual issues with power-to-liquids without strong behind-the-meter additionality for clean electricity. That is NOT my primary issue with this application though. My main concern is my inability to parse the real-world CO2 sourcing from HIF's application, as they list several potential sources without giving any breakdown of volumes or % from each source (it may have been redacted, of course). My rudimentary understanding is that CO2 sourcing needs to be factored in for "e-fuels". Captured CO2 from fermentation in a corn ethanol plant is different than CO2 captured from steam methane reformation (SMR) of fossil-derived methane, for instance. The former utilizes carbon already present in the environment, utilized by the corn plant to synthesize sugars that are subsequently metabolized into useful energy and CO2 by the fermenting organisms. A circular carbon cycle. The latter indeed utilizes "waste" CO2, but this is still "new" carbon introduced into the environment via fossil methane. The two "CO2" molecules are not the same, nor should they be treated as such.

I promised to keep it short, so I won't get into into efficiencies of electrolysis, or methanol synthesis or efficiencies of larger hydrocarbon synthesis. As noted above, my primary issue is trying to better understand the exact breakdown of CO2 sources they intend to utilize in their synthetic processes. Taking CO2 derived from fossil sources IS NOT better than simply allowing that CO2 to vent to the atmosphere. In fact I would argue it is worse given the energy inputs and associated emissions necessary to collect and then transform that fossil CO2 via their proposed pathways into hydrocarbons that will be combusted into CO2 (and other components) anyhow.

In short, e-fuels utilizing fossil CO2 are potentially more harmful than simply allowing the CO2 from the initial use event (combustion, SMR, etc) to be vented into the environment. Additional environmental carbon is the issue, and HIF's pathways involving fossil-based CO2 do not address this issue. Carbon capture and sequestration of any fossil-based CO2 would be an example of addressing the additive carbon. I fully support any fuels they produce from non-fossil CO2, but am opposed to any "credit" given to fuels created from new fossil carbon because the end result is more carbon introduced into the environment combined with the additional emissions resulting from their synthetic process.

Sincerely,
Josh Kehoe MD

N/A