California ARB issues feedstock-only pathway for camelina-based fuels under LCFS; zero ILUC emissions results in very low CI fuels
The California Air Resources Board has issued Sustainable Oils Inc., a wholly owned subsidiary of Global Clean Energy Holdings, a feedstock-only pathway for the production of camelina-based fuels under the Low Carbon Fuel Standard (LCFS). The feedstock-only CI (carbon intensity) is 7.58 gCO2e/MJ.
A feedstock-only pathway allows a fuel producer interested in producing either biodiesel or renewable diesel from a camelina feedstock using Sustainable Oils’ proprietary seed varieties to combine the CI of this pathway for the production of a camelina oil feedstock with the carbon intensity components of the fuel producer’s specific fuel production and transportation processes. The feedstock-only pathway includes only the CI components for farming, agricultural chemicals, camelina transportation, and oil extraction.
For example, when combined with ARB’s generic North American producer profile, the Sustainable Oils feedstock-only pathway produces biodiesel and renewable diesel at CIs of approximately 19.1 gCO2e/MJ and 18.7 gCO2e/MJ, respectively. Lower CIs could be achieved by processors with more efficient production profiles.
As a comparison, ARB’s general pathway for soybean-based biodiesel finds a direct GHG contribution of 21.25 gCO2e/MJ; however, once indirect land use change (ILUC) emissions of 62 gCO2e/MJ are factored in, the total CI rises to 83.25 gCO2e/MJ. By contrast, ARB has determined that the greenhouse gas emissions from ILUC for the camelina pathway are zero.
Camelina sativa (camelina) is a member of the mustard family and a distant relative to canola. Camelina contains about 35 to 38% oil, which makes it suitable for biofuels production.
Camelina is primarily grown in Montana, eastern Washington, the Dakotas, and Alberta, Canada. Camelina has historically been grown in rotation with row crops or cereals, and has not been grown for human consumption; camelina meal can be used as livestock feed.
Camelina has been evaluated most intensively as a rotation crop that can fit into the traditional winter wheat, spring wheat and fallow crop cycles on dryland wheat farms. In addition to growing camelina on fallow wheat acreage, its agronomic attributes allow it to be inter-cropped with perennials, double-cropped with row crops and fit into other shoulder periods between primary crop harvesting and next crop planting.
Substituting fallow land with camelina production would not typically displace another crop, so it is unlikely that new land would need to be brought into agricultural use to increase camelina production.
ARB staff does not expect that the market dynamics of camelina with respect to other crops such as soy and wheat will change significantly in the near term—i.e., returns on camelina will remain relatively low, and farmers are not expected to grow camelina on land that would otherwise be used to grow cash crops with well-established prices and markets. Because camelina currently does not have other significant markets, expanding production and use of camelina for biofuel purposes is not likely to have impacts on other agricultural commodity markets. Therefore, ARB staff concluded, expanded camelina production is not likely to result in any significant indirect land use change impacts. Accordingly, the ILUC component in the pathway analysis is zero.
Should those conditions change, however, ARB staff will consider revising the zero ILUC emission factor.
Environmental advocacy groups NRDC, NWF and the Union of Concerned Scientists submitted a letter of support for this pathway and the approach it represents to feedstock development, as did the leading biofuels sustainability standard, the Roundtable on Sustainable Biomaterials (RSB).
Sustainable Oils has developed three proprietary camellia seed varieties with superior yields up to about 1,700 pounds of grain per acre, for an oil yield of up to about 670 pounds per acre, on average. Sustainable Oils has three more varieties of Camelina that are pending for submittal for patent, which will produce shorter gestation periods, greater yield, and increased seed size; these three see varieties are not included in the feedstock-only pathway.
This unique pathway approval, combined with our previous EPA RFS approval, lays the foundation for Sustainable Oils’ Camelina to play an expanded role in meeting the ambitious carbon reduction requirements of the CA LCFS in the coming years. By producing fuel with a CI as much as 60 g/MJ lower than other biofuels, obligated parties are able to meet their reductions with a fraction of the volume otherwise required as well as generate valuable LCFS credits in the process.—Richard Palmer, SusOils CEO