## C ARINATA 

## O IL 

## LCA D ATA

Prepared For:



## Agrisoma Biosciences Inc.

Suite 32 7

2

- 2026 Lanthier Drive
Ottawa, Ontario K4A 0N6

Prepared By



## (S&T) 2 

## Consultants Inc.

11657 Summit Crescent
Delta, BC
Canada, V4E 2Z2

Date: July 31

, 2013

# (S&T) 2 C ARINATA O IL LCA D ATA i 

## E XECUTIVE 

## S UMMARY

The U.S. Environmental Protection Agency (EPA) promulgated the Final Rule implementing changes to the renewable fuel standard program in the United States (RFS2) in 2010, which included specific categories for Biomass

- Based Dies el and Advanced Biofuels. This rule includes approved pathways, based on a lifecycle assessment of greenhouse gas (GHG) emissions, for various renewable fuels including soybean biodiesel and biodiesel produced from waste products. In order to be eligible u nder the RFS2 program as Biomass

- Based
Diesel or Advanced Biofuels, EPA had to determine whether biodiesel fuels have a 50% reduction of GHG emissions compared to the baseline diesel fuel.

The EPA has used two approaches to determining if a feedstock/fuel combination exceeds the minimum 50% reduction threshold. In the first approach a full direct and indirect analysis is undertaken with the suite of models used by the EPA. The second approach, used first for feedstocks like camelina, algae and waste produc ts is different. In the case of camelina, the EPA first determined that camelina was likely to be grown on fallow land and the production of camelina would not involve significant expansion of cropland . EPA also found limited

markets for camelina outside biofuel production. Based on these findings, EPA determined

there would be no direct or indirect land use change emissions. The direct GHG emissions from the production of camelina were then compared to soybean production emissions.

The EPA concluded that :

“Given that GHG emissions from camelina oil would be similar to the GHG emissions from soybean oil at all stages of the lifecycle but would not result in land use change emissions (soy oil feedstock did have a significant land use change impact but still met a 50% GHG reduction threshold), and considering differences in process emissions between soybean biodiesel and camelina

- based renewable diesel, we

conclude that renewable diesel from camelina oil will also meet the 50% GHG

emissions reduction threshol d to qualify as biomass based diesel and advanced fuel. Although some of the potential configurations result in fuel production GHG emissions that are higher than fuel production GHG emissions for soybean oil biodiesel, land use change emissions account fo r approximately 80% of the soybean oil to biodiesel lifecycle GHGs. Since camelina is assumed not to have land use change emissions, our analysis shows that camelina renewable diesel will qualify for

advanced renewable fuel and biomass

- based diesel RINs ev en for the cases with the highest lifecycle GHGs ( e.g., when all of the co

- products are used to generate RINs.)

. ”

Carinata is a very similar crop to camelina. It is expected to utilize a similar area of land that camelina is proposed to be grown on. A high percentage of this land is expected to be land that is currently fallow in the existing multi

- year crop rotations. Just as the EPA concluded that camelina production would not have land use change emissions, they should also concluded that carinata produc tion will not have indirect land use emissions.

The direct emissions for carinata production may be slightly higher than they are for camelina production but the emissions for oil extraction will be lower and the emissions for processing the oil into biodi esel or renewable diesel will be similar. Overall the direct emissions from the production of renewable fuels from carinata will easily meet the 50% emission threshold established under the RFS 2 program.

# (S&T) 2 C ARINATA O IL LCA D ATA ii

# (S&T) 2 C ARINATA O IL LCA D ATA iii 

## T ABLE OF 

## C ONTENTS

EXECUTIVE SUMMARY

................................ ................................ ................................ ............... I

TABLE OF CONTENTS

................................ ................................ ................................ ............... III

LIST OF TABLES

................................ ................................ ................................ ........................ II I

LIST OF FIGURES

................................ ................................ ................................ ..................... IV

1. INTRODUCTION

................................ ................................ ................................ .................... 1

1.1 C AMELINA VS

. C ARINATA

................................ ................................ ................................ . 1

2. CARINATA PROPERTIES, PRODUCTION, AND DEMA ND

................................ ................ 3

2.1 C ARINATA P ROPERTIES

................................ ................................ ................................ ... 3

2.2 C ARINATA P RODUCTION

................................ ................................ ................................ .. 4

2.3 C ARINATA D EMAND

................................ ................................ ................................ ......... 6

2.4 M ARKET C ONDITIONS FOR C ARINATA O IL

................................ ................................ ......... 7

3. CARINATA AGRONOMICS

................................ ................................ ................................ ... 8

3.1 Y IELD 8

3.2 F ERTILIZER R EQUIREMENTS

................................ ................................ ............................ 9

3 .3 D IRECT E NERGY C ONSUMPTION

................................ ................................ ...................... 9

3.4 A GRONOMIC P RACTICES

................................ ................................ ................................ . 9

3.4.1 Tillage Practices

................................ ................................ ................................ ... 10

3.4.2 Residues Left in Field

................................ ................................ ........................... 10

3.5 C ARINATA P RODUCT ION E MISSIONS

................................ ................................ .............. 11

4. CARINATA SEED CRUSHI NG

................................ ................................ ............................ 12

4.1 P RODUCT Y IELDS

................................ ................................ ................................ .......... 12

4.1.1 Oil Yields

................................ ................................ ................................ .............. 12

4.1.2 Meal Yields

................................ ................................ ................................ ........... 12

4.2 E NERGY R EQUIREMENTS

................................ ................................ ............................... 12

4.3 C ARINATA F EED C O

- PRODUCTS

................................ ................................ ..................... 13

5. RENEWABLE FUEL PRODU CTION

................................ ................................ ................... 15

5.1 E NERGY U SE

................................ ................................ ................................ ................ 15

6. CONCLUSIONS

................................ ................................ ................................ ................... 16

7. REFERENCES

................................ ................................ ................................ ..................... 17



## L IST OF 

## T

ABLES

TABLE 2

- 1 CAMELINA AND CARINAT A PROPERTIES

................................ ...................... 4

T ABLE 2

- 2 COST AND RETURNS

................................ ................................ ........................ 6

TABLE 3

- 1 CROP YIELDS

................................ ................................ ................................ ..... 8

TABLE 3

- 2 CARINATA FERTILIZER USE

- 2022

................................ ................................ . 9

TABLE 3

- 3 CARINATA ENERGY USE

................................ ................................ .................. 9

# (S&T) 2 C ARINATA O IL LCA D ATA iv

TABLE 3

- 4 CARINATA RESIDUE ASS UMPTIONS

................................ ............................ 10

TABLE 3

- 5 GHG EMISSIONS COMPARISON

................................ ................................ .... 11

TABLE 4

- 1 CANOLA CRUSHING ENER GY REQUIREMENTS

................................ ......... 13

TABLE 4

- 2 CARINATA CRUSHING EN ERGY REQUIREMENTS

................................ ...... 13

TABLE 5

- 1 FUEL PROCESSING EMIS SIONS

................................ ................................ ... 15



## L IST OF 

## F IGURES

FIGURE 2

- 1 B. CARINATA FIELD

................................ ................................ ........................... 3

FIGURE 2

- 2 POTENTIAL CAMELINA R OTATIONS

................................ ............................... 5

FIGURE 2

- 3 US VEGETABLE OIL PRI CES

................................ ................................ ............ 7

FIGURE 4

- 1 CA RINATA PROCESSING

................................ ................................ ................ 12

# (S&T) 2 C ARINATA O IL LCA D ATA 1



## 1. I NTRODUCTION

The U.S. Environmental Protection Agency (EPA) promulgated the Final Rule implementing changes to the renewable fuel standard program in the United States (RFS2) in 2010, which

inc luded specific categories for Biomass

- Based Diesel and Advanced Biofuels. This rule includes approved pathways, based on a lifecycle assessment of greenhouse gas (GHG) emissions, for various renewable fuels including soybean biodiesel and biodiesel produce d from waste products. In order to be eligible under the RFS2 program as Biomass

- Based
Diesel or Advanced Biofuels, EPA had to determine whether biodiesel fuels have a 50% reduction of GHG emissions compared to the baseline diesel fuel. In the final rule s oybeans were the only commercial oilseed that was analyzed and approved. Subsequent to the Final
Rule, the EPA has analyzed canola and camelina and has approved both of these oilseeds. There are other oilseeds that are undergoing EPA review at this time.

T he approvals for canola and camelina involved different approaches by the EPA. The canola pathway was thoroughly analyzed by the EPA and added to all of the models that are used in the RFS approval process. The camelina approach was different. The EPA firs t determined that camelina was likely to be grown on fallow land and the production of camelina would not involve significant expansion of cropland and thus there would be no direct land use change emissions. EPA also determined that camelina has limited m arkets and is not internationally traded, and, thus, there would be no significant indirect land use change emissions. The direct GHG emissions from the production of camelina were t h en

comp a red to soybean production emission s to arrive at the conclusion that the GHG emission reductions for camelina biodiesel, renewable diesel and jet fuel would be greater than the 50% required in the RFS2 program.

Agrisoma Biosciences Inc. will be submitting a request to the U.S. EPA to consider the

inclusion of carinata biodiesel and renewable diesel (including heating oil and jet fuel) in the RFS2 program as Biomass

- Based Diesel, which is an Advanced Biofuel. The petition request also includes the same biofuels as have been approved for camelina. The inclusion

of c arinat a

- based biofuels will require the EPA to determine if the lifecycle GHG emissions associated with all stages of the process meets the eligibility requirements of the program.

Due to the proprietary nature of the LCA modeling framework established by the EP A under the RFS2 program, a full LCA analysis of c arinata

- based biofuels is not possible outside of the EPA. This work documents the practices of growing carinata , crushing the seeds to extract the oil, and then processing the oil to produce renewable dies el. These practices and emissions are compared to the information that the E PA has published for camelina and soybeans (EPA, 2013). The information in this report should be sufficient to allow the EPA to determine that carinata oil is sufficiently similar to camelina to rely on the same analysis or,
as necessary, to undertake its modeling work.

1.1 C AMELINA VS

. C ARINATA

The EPA approved a camelina pathway as a pot ential feedstock under the same biodie sel and renewable diesel (which includes die sel fuel, jet fue l, and heating oil) pathways for which soybean oil c urrently qualifies. The EPA also incl uded a pathway for naphtha and LPG produced from camelina oil through hydrotreating. The EPA did not undertake a full lifecycle modeling exercise for camelina; instead they relied on an analysis of the potential for camelina production to avoid land use effects

. This analysis showed that most camelina is expected to be grow n on land that would otherwise be fallow and therefore would not have significant land use impacts . The second aspect of the EPA’s analysis involved a comparison of the direct emissions from the fuels and chemicals involved in the production of camelina

# (S&T) 2 C ARINATA O IL LCA D ATA 2

compared to those for the production of soybeans. From this analysis, it was concluded that

the dire ct emissions from camelina production and conversion to biodiesel or renewable diesel would be less than the emissions for soybean production and conversion to renewable

fuels.

In this report the data that is required to undertake a lifecycle assessment of carinata is provided as well as a comparison to the information on camelina and soybean production and processing that the EPA relied on in their approval of the camelina pathways. This is

done to demonstrate that carinata renewable diesel will also not h ave land use effects and the same approval process for camelina can be used for carinata.

# (S&T) 2 C ARINATA O IL LCA D ATA 3



## 2. C ARINATA 

## P ROPERTIES



## , P RODUCTION



## , AND 

## D EMAND

Brassica carinata is an oilseed crop that is commonly referred to as Ethiopian mustard. B.

carinata (or simply carinata ) is extremely well suited to production in semi

- arid areas. It offers good resistance to biotic stressors, such as insects and disease, as well as abiotic stressors, such as heat and drought (Getinet et al, 1996 )

. Agriculture and Agri

- Food Canada have dev eloped varieties that offer growers high yields, high oil content and are ideally suited to semi

- arid growing conditions commonly found in the

southern Prairies of Canada and the Northern Plains of the US and as an off

- season winter crop in the southern US

.

Figure 2

- 1 B

. Carinata Field

Minton, Saskatchewan

– June 29, 2012

2.1 C ARINATA P ROPERTIES

The crop has many of the same characteristics as camelina in terms of drought and heat

tolerance

. C ommercial variet ies of c arinata, however, ha ve a higher yield and oil content while maintaining a high protein content. The protein content results in a meal protein by

product with crude protein levels approaching soybean. The carinata yield and oil content

shown in the following table are from 2012 field trials. There is the potential for yields to

# (S&T) 2 C ARINATA O IL LCA D ATA 4

increase as seed development continues. The current development plan projects a yield

in crease of over 15% by 2022 to 2.1 t/ha based on the implementation of marker assisted

a nd double haploid breeding and the launch of hybrid varieties. Additionally, oil content is expected to increase an additional 2% points while maintaining protein levels in the meal co

product

.

Table 2

- 1 Came lina and Carinata Properties

Camelina (EPA Projection) Carinata 2012

Yield, t/ha 1.8 2.1

Oil content 36 % 44%

Protein Content 30% 28%

2.2 C ARINATA P RODUCTION

Carinata is expected to be grown in semi

- arid conditions where other crops typically perform poorl y or when a fallow period is still included in the crop rotations. The fallow period helps to preserve soil moisture for the crop that succeeds the fallow period. Research ( Angus et al, 1996) clearly shows the benefit of incorporating a Brassica crop into a predominantly wheat only rotation with this effect being even great er in moisture limited environments where carinata will be grown. This is the identical strategy that is being developed for camelina production in the US Northern Plains and for Canada. The rotations shown in the EPA Figure 1 in the Final Rule making for the camelina pathway applies equally well to carinata as it

does to camelina. This figure is reproduced below.

Carinata is also showing promising results as an off

- season winter cover cro p in the

southeastern US. Trials have been carried out in Florida and Arizona with support from the

USDA and others. Cropland in these geographies are either left fallow or have a winter cover crop to prevent soil erosion and carinata’s biotic and abiotic stress tolerance has demonstrated it can withstand the highly variable weather conditions in these areas to produce an economical yield.

# (S&T) 2 C ARINATA O IL LCA D ATA 5

Figure 2

- 2 Potential Camelina Rotations

The EPA did their own analy sis of the cost of production and producer returns from camelina production and this analysis supported the position that the low returns for the crop. They reported that;

# (S&T) 2 C ARINATA O IL LCA D ATA 6 Camelina is most likely to be planted on soil with lower moisture and nutrients wher e other rotation crops are not viable. Because expected returns on camelina are relatively uncertain, farmers are not expected to grow camelina on land that would otherwise be used to grow cash crops with well

- established prices and markets.
Instead, farme rs are most likely to grow camelina on land that would otherwise be left fallow for a season. The opportunity cost of growing camelina on this type of land is much lower. As previously discussed, this type of land represents the 9 million acres currently b eing targeted for camelina production.

The same cost and return information has been calculated for c arinata and compared to the

EPA c amelina calculations as shown in the following table. The same prices have been used for the chemical inputs. The differe nces are in the fertilizer quantities, seed prices and the selling price of the product. It is expected that c arinata will have a higher selling price due to the higher oil content.

Table 2

- 2 Cost and Returns

Inputs 2022 Camelina 2022 Carinata

Herbicides: Glysophate (Fall) $7.00 $7.00
Glysophate (Spring) $7.00 $7.00

Post $8.00 $8.00

Seed $7.20 $7.20

Fertilizer: Nitrogen Fertilizer $40.00 $ 6 0.00
Phosphate Fertilizer $15.00 $ 30 .00

Sub

- T otal $84.20 $ 11 9.20 Logistics:
Planting Trip $10.00 $10.00
Harvest & Hauling $25.00 $25.00

Total Cost $119.20 $ 1 54.20

Yields Lb/acre 1

, 650 1

, 865

Price $/pound $0.12 $0.14
Total Revenue at avg prod/pricing $198 $261.10

Returns $/acr e $78.80 $ 1 06.90

The Net Returns for c arinata are $ 2 8 /acre greater than for Camelina if the realized pr i ce is 2 cents/pound more and $9 less if the price is the same as camelina and this small d ifference would not change the EPA conclusion with respect to the competition for land between low return crops like camelina and carinata and the bette r established cash crops.

2.3 C ARINATA D EMAND

Carinata demand is closely linked to biofuel demands. The seed development is driven by industrial applications (including fuels) and not by food demand.

# (S&T) 2 C ARINATA O IL LCA D ATA 7

2.4 M ARKET C ONDITIONS FOR C ARINATA O IL

Carinata oil will no t be used for food purposes but it could displace some oils in industrial applications. Its price is therefore expected to move in the same general pattern as other fats

and oils.

The price patterns of various competing oils are shown in the following figu re.

Figure 2

- 3 US Vegetable Oil Prices

Sources: Monthly Feedstuff Prices, USDA Agricultural Marketing Service

# (S&T) 2 C ARINATA O IL LCA D ATA 8



## 3. CARINATA AGRONOMICS

As c arinata is a new crop the detailed history of crop production in terms of yields, fertilizer and fuel requirements is not available. The data that is available can be compared to the camelina and soybean data that the EPA used for the approval of the camelina pathway.

3.1 Y IELD

A number of field trails have been undertaken in re cent years. The yield data from these trails is summarized in the following table. Research plots that experienced problems such as drought, hail, or insect damage have been removed from this list.

Table 3

- 1 C rop Yields

Year Country Prov/State Site Yield , kg/ha Co

- operator

A100 A110 Average

2009 Canada SK Scott 4321 4321 AAFC (Scott)

2010 Canada SK Scott 2227 2299 2263 AAFC (Scott)

2011 Canada SK Indian

Head 2843 3057 2950 IHARF (Indian Head Ag

Rese arch Farm)

2012 Canada MB Melita 1910 1810 1860 MAFRI (Manitoba Ag,

Food and

Rural Initiatives)

2012 Canada SK Indian

Head 1595 1802 1699 IHARF

2012 Canada SK Swift

Current 1166 1197 1182 WCA

2012 Canada SK Stewart Valley 1048 1048 Westwind

2012 Can ada SK Vanguard 2619 2619 Westwind

2012 Canada SK Aneroid 788 788 Westwind

2012 Canada AB Lethbridge 2794 2650 2722 Farming

Smarter

2012 Canada AB Lethbridge 2632 2632 HyTech

2012 Canada AB Kipp 3485 3485 AgQuest

2012 US MT Havre 1298 1298 MSU

2 012 US ND Drake 2027 2069 2048 NDSU

2012 US SD Pierre 497 497 SDSU
Average 2094

The average yield of 2,094 kg/ha is equal to 1,865 lb/acre. Yields in research plots are always higher than the yields in commercial production. As with the camelina ruling we have used the research plot yield (highest technically feasible) as an indication of the projected commercial yield in 2022.

# (S&T) 2 C ARINATA O IL LCA D ATA 9

3.2 F ERTILIZER R EQUIREMENTS

In the following table the information for 2022 has been forecast. As stated previously the

2022 commercial yield is based on the current yields from research plots. The fertilizer requirements have been kept at the same rate per acre. This estimate is compared to the data used by the EPA in the camelina approval

.

Table 3

- 2 Carinata Fertilizer Use

- 2022

Carinata Carinata Camelina

Per Acre Per ton oil Per ton oil

Yield 1,865 lbs 2. 27 tons 3.36

Oil 820 lbs 1.0 1.0 Nitrogen 60 lbs 146 135 Phosphorus 30 lbs 73 50

Potassium 0 0 34

Herbicide 0 0 9.25

Pesticide 0 0 0

The land that carinata is expected to be grown on generally has high potassium levels and augmentation with potash fertilizer is not required. Given the similar protein contents of camelina and carinata, they should have similar nitrogen input requirements. Crops that follow a fallow field have lower nitrogen requirements than crops planted on continually cropped land. The difference in the previous table could be the difference between crops planted on fallow land vs. crops planted on co ntinually planted land.

3.3 D IRECT E NERGY C ONSUMPTION

The farm energy used by the EPA for camelina was 3.5 gallons of diesel fuel per acre. Fuel consumption is usually a function of just the area and not the production. Given the similarities in production pr actices between carinata and camelina the same value is used for

carinata.

Table 3

- 3 Carinata Energy Use

Camelina Carinata Camelina Carinata

Per acre Per Acre Per ton oil Per ton oil

Yield 1,650 lbs 1, 865

Gasoline 0 gal 0 gal

Diesel 3.5 gal 3.5 gal 11.78 9.94

3.4 A GRONOMIC P RACTICES

The specific agronomic practices employed by feedstock producers can have a significant impact on the GHG emissions resulting from the growing of feedstock. Some of the prim ary practices are discussed below.

# (S&T) 2 C ARINATA O IL LCA D ATA 10

3.4.1 Tillage Practices

Low return crops planted on moisture deficient soils usually adopt reduced tillage or no tillage practices to lower operating costs and conserve soil moisture. The fuel consumption

value used for camelin a and carinata reflect that practice.

A survey of production practices undertaken by the Canola Council of Canada in 2011 found the average fuel use for canola production in western Canada was 3.11 gallon/acre ((S&T) 2

, 2013). This is confirmation of the 3. 5 gallons used for the camelina analysis and proposed for the carinata analysis.

3.4.2 Residues Left in Field

Crop residues and roots that are left in the field are beneficial for soil carbon but they do

release N 2 O emissions as they decompose. There is very lit tle data on the composition of

the carinata residue. Since the carinata properties are similar to canola in many respects and they are from the same brassica family, w e have assumed that they are the same as canola as shown in the following table. The valu es are from Janzen (2003).

Table 3

- 4 Carinata Residue Assumptions

Parameter Value
N content of above ground residue (fraction of dry mass) 0.0080 Ratio of above ground residue weight to weight of crop or pr oduct harvested 2.31 N content of below ground residue (fraction of dry mass) 0.0100 Ratio of below ground biomass weight to weight of crop or product harvested 0.58

# (S&T) 2 C ARINATA O IL LCA D ATA 11

3.5 C ARINATA P RODUCTION E MISSIONS

The EPA calculated the GHG emissions for camelina pro duction and for soybean production and presented the results on a kg/mmBTU of fuel basis. The results are shown in the following table and the carinata results , calculated from the data presented in this report, are also shown for comparison. This presenta tion of the data ignore s the role of the co

- product

meal.

Table 3

- 5 GHG Emissions Comparison

Parameter Camelina Soybean Carinata Kg CO 2 eq/mm BTU fuel

N 2 O 22 9

– 12 24 Nitrogen Fertilizer 7 1

– 3 7 Phosphorous Fertilizer 1 0

– 2 1

Potassium Fertilizer 0 0

– 2 0

Herbicide 3 0

– 2 2

Pesticide 0 0

– 2 0

Diesel 5 7

– 20 4

Gasoline 0 3

– 5 0

Total 38 21

– 47 39

The carinata GHG emission results are slightly higher than the camelina results and just in

the mid

- range of the soybean emission results.

# (S&T) 2 C ARINATA O IL LCA D ATA 12



## 4. C ARINATA 

## S EED 

## C RUSHING

Carinata is very similar to canola in terms of its properties and t he crushing of and extraction of the oil is expected to be identical. The canola processing process is shown in the following figure.

Figure 4

- 1 C arinata Processing

4.1 P RODUCT Y IELDS

The c arinata crushing pro cess produces two products: meal, and oil. Both products have significant economic value.

4.1.1 Oil Yields

The oil content of the carinata seeds is 44%. Most of this can be extracted through conventional processing. It will be assumed that the oil yield is 42% o f the seed weight. This means that 2.38 pounds of seed will be required to produce one pound of refined oil.

4.1.2 Meal Yields

The meal yield is the remainder of the oilseed. With an oil extraction rate of 0.42, the meal yield will be 0.58 pounds per pound of oi l seed or 1.38 pounds of meal per pound of oil.

4.2 E NERGY R EQUIREMENTS

The EPA reported the energy requirements of camelina and soybean oil in their approval of camelina. It has been assumed that the energy requirements for carinata are identical to

those of canola. The crushing energy for canola has been previously reported to the EPA in

# (S&T) 2 C ARINATA O IL LCA D ATA 13

the canola oil pathway LCA data submitted to the EPA for the canola oil RFS2 pathway ((S&T) 2 , 2010).

A survey of the canola crushing plants was undertaken by Canadian Oilseed Processors Association for this work. A total of 10 plants in Canada and the United States participated in the survey. All of the plants used natural gas as their source of thermal energy. To the extent possible, the plants normalized their energy require ments to produce the quality of canola oil required for biodiesel production as opposed to the quality used for human food applications. The results from the survey are summarized in the following table.

Table 4

- 1 Canola Crushing Energy Requirements

Per tonne of Canola crushed Per tonne of Oil produced

Electricity Purchased, kWh 49 114.5
Natural Gas Purchased, GJ 1.0 2.34 Total Energy, GJ 1.18 2.75

This information has been converted to the basis that the EPA used in the camelina approval and is compared to the EPA data in that approval document. It was not possible to exactly duplicate the EPA GHG emissions using the emission factors for electricity (219,823 g

CO 2 eq/mmBTU) and natural gas (58,818 g CO 2 eq/ mmBTU) used in the EPA Final Rule files but the results are quite close.

Table 4

- 2 C arinata Crushing Energy Requirements

Item Soybeans Camelina Carinata Units

Material Inputs:

Beans or Seeds 5.38 2.9 2.38 Lbs. Energy Inputs: Electricity 374 47 76 Btu.

Natural Gas & Steam 1,912 780 428 Btu. Outputs: Refined vegetable oil 1 1 1 Lbs.

Meal 4.08 1.85 1.38 Lbs.

GHG Emissions 1 213 64 gCO 2 e/lb

refined oil

GHG Emissions 2 195 56 42 gCO 2 e/lb

refined oil

The carinata GHG emissions per pound of oil extracted are lower than the emissions reported by the EPA for camelina and soybean oils.

4.3 C ARINATA F EED C O

- PRODUCTS

Mustard meal is an approved feed for cattle and sheep at the 10% inc lusion level in the United States. It has been approved at this level since 1973. Brassica carinata is a cultivated mustard species commonly referred to as Ethiopian Mustard.

1 Reported by EPA.

2 Calculated using Emission Factors from EPA Final Rule

# (S&T) 2 C ARINATA O IL LCA D ATA 14

Brassica carinata meal (BCM) is produced following standard solvent extraction of the oil

from the seed. The press cake is a high protein, low fiber meal suitable for feeding beef cattle under the AAFCO definition 71.30, Mustard Meal, Solvent Extracted.

In the European Union, Mustard seed meal is an approved feed material and is define d as the product obtained by the extraction of volatile mustard oil from mustard seed.

The composition of BCM is very similar to that of canola meal and is expected to perform similarly in animal diets.

# (S&T) 2 C ARINATA O IL LCA D ATA 15



## 5. R ENEWABLE 

## F UEL 

## P RODUCTION

Renewable fuel production using carinata oil is identical to the production of renewable fuel produced from camelina or soybean oil. The following comments are provided on the values used by the EPA in their RFS analysis.

5.1 E NERGY U SE

The energy requirements for converting a vegetabl e oil to biodiesel, renewable diesel, or renewable jet fuel are quite similar for the various vegetable oils. The EPA provided the following table in the camelina approval.

Table 5

- 1 Fuel Processing Emissions

Feedstock Production process Oil extraction Processing Total kgCO 2 e/mmBtu
Soybean Oil Trans

- Esterification 14

- 1 13

Camelina Oil Trans

- Esterification 4

- 1 3

Camelina Oil Hydrotreating

Maximized for Diesel 4 8 12

Camelina Oil Hydrotreating

Maximized for Jet 4 11 14

The carinata oil extraction emissions will be less than those for soybeans and camelina and the fuel processing emissions should be similar to these other two feedstocks.

# (S&T) 2 C ARINATA O IL LCA D ATA 16



## 6. C ONCLUSIONS

The EPA concluded that:

“ Given that GHG emi

ssions from camelina oil would be similar to the GHG em issions from soybean oil at all stages of the lifecycle but would not result in land use change emissions (soy oil feedst ock did have a significant land use ch ange impact but still

met a 50% GHG reduct ion threshold), and con sidering differences in process

emis sions between soybean biodiesel and camelina

- based renewable diesel, we

conclude that renewa ble diesel from came lina oil will also meet the 50% GHG

e missions reduction threshold to qual ify as bioma ss based diesel and adva nced fuel. Although some of the potentia l configurations result in fuel pr oduction GHG emissions that are higher than fuel production GHG emissions for soybean oil
biodiesel, land u se change emissions account for approxim ately 80% o f the soybean oil to biodiesel lifecycle GHGs. Since camel ina is assumed not to have land use change emissions, our analysis shows that camelina renewable diesel will qual ify for

advanced renewable fuel and bio mass

- based diesel RINs even for the c ases with the highest lifecycle GHGs ( e.g., when all of the co

- products are used to generate RINs.)”

Carinata is a very similar crop to camelina. It is expected to compete for the same area land that camelina is proposed to be grown on. A high percentage of this la nd is expected to be land that is currently fallow in the existing multi

- year crop rotations. In addition, there is a limited use for Carinata, and no internationally traded markets. Just as the EPA concluded that camelina production would not have land u se change emissions, they should also concluded that carinata production will not have land use emissions.

The direct emissions for carinata production may be slightly higher than they are for camelina production but the emissions for oil extraction will b e lower and the emissions for processing the oil into biodiesel or renewable diesel will be the same . Overall the direct emissions from the production of renewable fuels from carinata will easily meet the 50%

emission threshold established under the RFS 2 program.

# (S&T) 2 C ARINATA O IL LCA D ATA 17



## 7. R EFERENCES

(S&T) 2 Consultants Inc. 2010. Canola LCA Data.

(S&T) 2 Consultants Inc. 2013. Palm Oil and Biofuel Update. http://www.ghgenius.ca/reports/FinalReportPalmOilUpdat e.pdf

Angus, J., Kirkegaard, J., Peoples, M., Ryan, M., Ohlander, L., Hutton, L. 2011. A review of

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- crop benefits of brassicas. 17 th Australian Research Assembly on Brassicas. Wagga Wagga, August 2011. http://www.australianoilseeds.com/__data/assets/pdf_file/0005/8294/S6

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Getinet A, Rakow G, Downey RK. 1996. Agronomic performance and seed quality of Ethiopian

mustard in Saskatchewan. Can.J . Pl. Sci. 76: 387

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Janzen HH, Beauchemin KA, Bruinsma Y, Campbell CA, Desjardins RL, Ellert BH, Smith EG. 2003. The fate of nitrogen in agroecosystems: an illustration using Canadian estimates. Nutrient Cycling in Agroecosystems 67:85

– 102. http://www.springerlink.com/content/qg1uq482l4650624/

US EPA. 2013. Final Rule. Identification of Additional Qualifying Renewable Fuels under the Renewable Fuels Program. Federal Register. Volume 78 , No. 43, Tuesday March 5, 2013. http://www.gpo.gov/fdsys/pkg/FR

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