The National Corn Growers Association submitted comments on the updated carbon intensity (CI) scores being considered for the California Low Carbon Fuel Standard Program to the California Air Resources Board this week. The comments, which related specifically to the direct CI scores, follow comments NCGA submitted in March pertaining to the preliminary indirect CI scores assigned to corn ethanol.
In a short letter from NCGA President Martin Barbre, the association explained that, while it was pleased to see the preliminary scores ethanol received for carbon intensity using the new lifecycle analysis model, much scientific data supporting the benefits of ethanol has yet to be incorporated.
“We are pleased to see the preliminary CI scores from the new GREET have decreased for corn ethanol,” Barbre said in the letter. “However, we feel there is much scientific data that has been collected and peer-reviewed and should be reflected in these calculations. Without having the actual model available to evaluate, namely, CA-GREET 2.0, it is difficult to delineate our suggestions.”
Notably, the preliminary scores CARB presented during an August 22 meeting for ethanol made with the co-products of dry and wet distillers grains showed a 15 and 16 percent reduction respectively. At the same time, the preliminary scores assigned to many other fuels, such as compressed natural gas, increased.
The comments noted that NCGA looks forward to CARB’s release of the new model and to providing input on the assumptions and data used in the calculation of corn ethanol scores.