California Air Resources Board

We kindly request consideration of adding to CCR Section
95489(c)(1)(A), Chemistry Replace Steam, as an innovative
production method. This will incentive crude producers to stop
using steam to extract heavy oil, reducing emissions in California's most disadvantaged communities while reducing overall fossil fuel demand.

Approving this incentive could reduce oil extraction emissions 61 million tons of CO2e, eliminating 1.1 billion mcf of natural gas
burned by 2030. Reducing California's high carbon intensity by more than 60%. California producers will deliver the cleanest crude to California refineries, reducing emissions, imports, costly refinery upgrades all while supporting a cleaner transition.

The chemistry proposed is plant based, pH neutral and
biodegradable. This is safer, cleaner and more expensive than
steam. Which is why approval of this innovation is necessary to
accomplish the mission of CCR Section 95489. All approved
innovations in 95489(c)(1)(A) are aimed at reducing, replacing or
eliminating burning natural gas, either for steam or electricity.
Approved innovations are reducing around 55,000 tons CO2e per year. Approving this innovation reduce millions of tons within the first two years.

The biggest opportunities in O&G are the dirtiest production
methods, which is steam in California and Canada. Next would be heavier oils from Alaska North Slope.

This chemistry has so many other applications than just oil and
gas such as an all-natural firefighting suppression agent, lower emissions in agriculture, water treatment, enhanced oil recovery, eliminating solvents and harmful cleaning products, soil remediation, and the opportunities keep multiplying.

Attached is a technical explanation of a chemistry that replaces steam. Also included is an application. The chemistry proposed is plant based, pH neutral and biodegradable, that is 13x lower carbon intensity than steaming.

Thank you for creating California's clean transition.