Return-Path: Received: from server.64xmedia.com by server.64xmedia.com with LMTP id oNH8HdMhDmOsQwAAdUq3JA (envelope-from ); Tue, 30 Aug 2022 10:42:27 -0400 Return-path: Envelope-to: directory@aicenergycorp.com, smelk@aicenergycorp.com Delivery-date: Tue, 30 Aug 2022 10:42:27 -0400 Received: from mta-131b.oxsus-vadesecure.net ([135.148.117.229]:51455 helo=nmtao101.oxsus-vadesecure.net) by server.64xmedia.com with esmtps (TLS1.2) tls TLS_ECDHE_RSA_WITH_AES_128_GCM_SHA256 (Exim 4.95) (envelope-from ) id 1oT2Rf-0004U9-53; Tue, 30 Aug 2022 10:42:27 -0400 DKIM-Signature: v=1; a=rsa-sha256; bh=fw/exqlNv6EYXAk+gtanP1lr/oWBtX8hpuNxoq oOkb8=; c=relaxed/relaxed; d=webcom.xion.oxcs.net; h=from:reply-to: subject:date:to:cc:resent-date:resent-from:resent-to:resent-cc: in-reply-to:references:list-id:list-help:list-unsubscribe: list-subscribe:list-post:list-owner:list-archive; q=dns/txt; s=mail1; t=1661870484; x=1662475284; b=lNNcOlISzNG45Zj20bVjikeClZcRqIg7GvOdEJl+f 2IxUDFY1l5DHZIY0/5NLEFIyoZ+DfbF7FVGjuVn268mqv4PCFM62Pixix1gzPEMKoRNfuJh CJcbHHad3E0GgDG+Md+qsHSmG95+16fYWKEEnUDF9A6OBMy/92jL/lRoqJszx/F/qXyuWVx vajcNvpJ+JgHRdi6S3zn0N/2VhYBVKr6iIwH5qzqi5mecBOt6l/9UXRp/2mGhG5Fy2gKFv5 0EMPkpIXIAwsVeeN4PX1+R9cZ+d+kyaBYD+LqxE05j1R5kVHJwQUBQZQ+x0IwRHVAO54wjm cDp7alQMqJ0hfORDA== Received: from proxy-7.proxy.cloudus.ewr.xion.oxcs.net ([24.230.175.2]) by smtp.oxsus-vadesecure.net ESMTP oxsus1nmtao01p with ngmta id 46ad6ac9-1710266630c5f621; Tue, 30 Aug 2022 14:41:23 +0000 From: "Kathleen Spilman, P.E." To: "Snow Melk @AIC" , , "'John Melk'" Cc: References: <3A662963-5F57-AC48-A002-A14C0845E14A@hxcore.ol> <000001d8bc7d$846e3aa0$8d4aafe0$@keitu.com> In-Reply-To: <000001d8bc7d$846e3aa0$8d4aafe0$@keitu.com> Subject: Answers to Snow's Questions - Canola Pathway Date: Tue, 30 Aug 2022 09:44:56 -0500 Organization: Keitu Engineers & Consultants, Inc. Message-ID: <001601d8bc7f$13e71750$3bb545f0$@keitu.com> MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="----=_NextPart_000_0017_01D8BC55.2B110F50" X-Mailer: Microsoft Outlook 16.0 Thread-Index: Adi8fuuRWovQPZgMR4mQZ5bEM67OHA== Content-Language: en-us Authentication-Results: oxsus-vadesecure.net; auth=pass smtp.auth=49@428034 smtp.mailfrom=kspilman@keitu.com; X-Spam-Status: No, score= X-Spam-Score: X-Spam-Bar: X-Ham-Report: X-Spam-Flag: NO This is a multipart message in MIME format. ------=_NextPart_000_0017_01D8BC55.2B110F50 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Short Version =20 * Canola likely is =E2=80=93 but no evidence on internet because no one = has apparently applied for it. Would take a phone call to California = agency to confirm either way. * Canola will almost certainly be granted federal credits. But still in = the process but we will know in a couple of months * Soybean pathway is for sure. We need to officially say soybean oil for = now. Especially if the USDA is asking the question as that is what the = IDU data is on. =20 Long Version: =20 Currently, the use of canola as a feedstock as an approved and = recognized pathway for SAF via the hydrotreating process depends on the = government entity being asked about. It would appear the California Air = Resource Board (CARB) has approved a canola pathway for alternative jet = fuel production to generate low carbon fuel standard (LCFS) credits. = CARB has a temporary pathway for alternative jet fuel which allows for = =E2=80=9Cany feedstock derived from plant oils (excluding palm oil and = palm derivatives).=E2=80=9D To date, only plants using tallow as a = feedstock have submitted to and received approval from CARB an = application for the ability to generate LCFS credits with the production = of alternative jet fuel. Phillips 66 has submitted and received = approval from CARB to use canola oil as a feedstock for the production = of renewable diesel. =20 On the federal side, the US Environmental Protection Agency (EPA) has = not finalized a ruling to give canola oil an approved and recognized = pathway for renewable diesel or SAF via the hydrotreating process to = generate Renewable Identification Number (RIN) credits. However, the = EPA issued for public comment on April 18th a pathway for canola to = produce RINs for renewable diesel, renewable jet fuel, renewable = naphtha, and renewable LPG. The public comment has closed and a final = ruling is expected sometime in the month of September according to the = US Canola Association. =20 The use of soybean oil as a feedstock for the production of renewable = diesel and renewable jet fuel using the hydrotreating process has an = approved pathway to generate RIN credits and an apparent approved = pathway to generate LCFS credits. The SAFuels X facility would use = soybean oil as its feedstock until canola oil is approved to generate = RIN credits. =20 Sincerely, Phillip Stack =20 From: Snow Melk >=20 Sent: Monday, August 29, 2022 5:08 PM To: Kathleen Spilman P.E. > Cc: 'Kristopher Keller' >; = pstack@keitu.com =20 Subject: Need to answer=20 =20 Kathy=20 Can you help us answer it ? =20 =20 =20 =20 =20 Renee L. Melk VP / Chief Operation Officer =20 Phone: 702.685.1118 =20 Direct: 702.508.1908 Email: smelk@aicenergycorp.com =20 =20 2840 S. Jones Blvd. Ste 1 Las Vegas, NV 89146 =20 www.aicenergycorp.com=20 =20 ------=_NextPart_000_0017_01D8BC55.2B110F50 Content-Type: text/html; charset="UTF-8" Content-Transfer-Encoding: quoted-printable

Short Version

 

  • Canola likely is = =E2=80=93 but no evidence on internet because no one has apparently = applied for it.=C2=A0 Would take a phone call to California agency to = confirm either way.
  • Canola will almost = certainly be granted federal credits.=C2=A0 But still in the process but = we will know in a couple of months
  • Soybean pathway is for sure. We need to officially say soybean oil = for now.=C2=A0 Especially if the USDA is asking the question as that is = what the IDU data is on.

 

Long = Version:

 

Currently, the use of = canola as a feedstock as an approved and recognized pathway for SAF via = the hydrotreating process depends on the government entity being asked = about.  It would appear the California Air Resource Board (CARB) = has approved a canola pathway for alternative jet fuel production to = generate low carbon fuel standard (LCFS) credits.  CARB has a = temporary pathway for alternative jet fuel which allows for =E2=80=9Cany = feedstock derived from plant oils (excluding palm oil and palm = derivatives).=E2=80=9D  To date, only plants using tallow as a = feedstock have submitted to and received approval from CARB an = application for the ability to generate LCFS credits with the production = of alternative jet fuel.  Phillips 66 has submitted and received = approval from CARB to use canola oil as a feedstock for the production = of renewable diesel.

 

On the federal side, the US Environmental = Protection Agency (EPA) has not finalized a ruling to give canola oil an = approved and recognized pathway for renewable diesel or SAF via the = hydrotreating process to generate Renewable Identification Number (RIN) = credits.  However, the EPA issued for public comment on April = 18th a pathway for canola to produce RINs for renewable = diesel, renewable jet fuel, renewable naphtha, and renewable LPG.  = The public comment has closed and a final ruling is expected sometime in = the month of September according to the US Canola = Association.

 

The use of soybean oil as a feedstock for the = production of renewable diesel and renewable jet fuel using the = hydrotreating process has an approved pathway to generate RIN credits = and an apparent approved pathway to generate LCFS credits.  The = SAFuels X facility would use soybean oil as its feedstock until canola = oil is approved to generate RIN credits.

 

Sincerely,

Phillip = Stack

 

From: Snow Melk <smelk@aicenergycorp.com> =
Sent: Monday, August 29, 2022 5:08 PM
To: Kathleen = Spilman P.E. <kspilman@keitu.com>
Cc: 'Kristopher Keller' <kkeller@keitu.com>; pstack@keitu.com
Subject: = Need to answer

 

Kathy 

Can you help us answer it ?

 

3DImage

 

 

3D"Logo<br><br>Description

Renee L. = Melk
VP / Chief = Operation Officer

 

Ph= one:&= nbsp;702.685.1118&nbs= p; 

Di= rect:  702.508.1908

Em= ail:&= nbsp;smelk@aicenergycorp.com

&n= bsp;

28= 40 S. Jones Blvd. Ste 1

La= s Vegas, NV 89146

&n= bsp;

www.aicenergycorp.com 

<= p = class=3DMsoNormal> 

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