1. The Directions should…

1. The Directions should provide information on the time period that the modelling is based on. I believe that the intention is for the modelling data to be from a 12 month period. This is a bit problematic for new plants that need a CI in order to market their product. They would have the data required for modelling their actual production by the time that a compliance report is required but depending on when they started, however it may not be 12 months’ worth. Some additional clarification would be beneficial.

2. I came across a case in the model where the default feedstock producing region for the plant was not representative of the actual region where the feedstock came from. For example, US East has the corn feedstock produced in US Central as the default case. A note in the directions that the feedstock production region on the Input Sheet rows 151 to 226 should reflect the actual feedstock production regions should be added to the directions.