While FORGE Hydrocarbons Corp (FORGE), an Ontario-based producer of renewable fuels (renewable diesel, renewable naphtha, sustainable aviation fuel) is supportive of the proposed updates for the addition of bio-based content (brown grease, fatty acid distillates, non-rendered cooking oil, biodiesel distillation bottoms) feedstocks, we ask that the models for brown grease and fatty acid distillates also specify the production of renewable diesel (whereas they currently only specify ‘biodiesel’), in order for the updates to be applicable to a wider range of renewable fuels producers. We also request that the fatty acid distillates feedstock category be amended to “fatty acid” feedstock to allow for a broader definition beyond distillates only. It is acknowledged that some “fatty acid” feedstocks require energy to be produced as usable feedstock and this will be accounted for as part of “Feedstock Production” inputs in the model. We are supportive of the updates to the Technical Guideline as described, with one exception. The Technical Guideline updates indicate: 1. Incorporating GHGenius model version 4.03c 2. Update to the Technical Guideline directions for calculating the lifecycle GHG emissions intensity of biodiesel from yellow grease. For #2, FORGE requests that the directions for calculating the lifecycle GHG emissions intensity from yellow grease specify the inclusion of renewable diesel in addition to biodiesel.
Submitted February 3, 2023 3:09 PM