From: Andersen-Schank, Karen

Sent: Fri Jul 27 13:06:55 2012

To: CleanFuelsAug2012

Subject: Clean Fuels Program Questions

Importance: Normal

 

We would like to request a copy of the OR-GREET model, per your proposed rules for the Oregon Clean Fuels Program. Do you mail that to us? If so, our US Mailing address is:

CHS

5500 Cenex Drive

Inver Grove Heights, MN 55077

Attn: Karen Andersen-Schank MS 222

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We also have the following questions. My phone # is listed below, if it’s easier to call vs. reply via email. We realize these are proposed rules, but we want to begin understanding the concepts as quickly as possible since we are likely to be a regulated party.

 

1. In the calculation of Carbon intensity for ethanol from corn in Table 3, does the GREET default at 64.80 basically represent dry mill, natural gas, and dry DGS?

2. When is the calculation of credits/deficits estimated to start? (1/1/2013?)

Or, is the calculation of credits/deficits dependent on phase 2?

 

3. Will the calculation of credits and deficits occur via an automated system like CA’s LRT? Will that automated system be ready by the time calculations are estimated to start?

4. If a regulated fuel is imported to Oregon, then exported out of Oregon, does a regulated party ignore that transaction for the purpose of calculating credits and deficits if the import and export happen in the same quarter?

5. What if the import of a regulated fuel to Oregon occurs in one calendar year and a credit/deficit is calculated. Then at a later date months later, the regulated fuel is exported out of Oregon. Does the regulated party have a means to adjust the credits or deficits created in the past?

 

Thank you.

Karen Andersen-Schank

Strategic Projects Coordinator

(651) 355-8528

karen.andersen-schank@chsinc.com

 

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