Comstock Mining calls on EPA to enhance regulations for biomass-derived intermediates

In Nevada, Comstock Mining Inc. announced its submission of comments to the U.S. Environmental Protection Agency calling for enhanced regulations governing the use of biomass-derived intermediates in the production of renewable fuels that qualify for federal incentives under the EPA’s Renewable Fuel Standard.

Comstock’s patented, patent-pending and proprietary portfolio of breakthrough Cellulosic Fuels technologies efficiently converts wasted, unused, widely-available, and rapidly-replenishable woody biomass into intermediates for the production of carbon neutral gasoline, renewable diesel, sustainable aviation fuel, marine fuel, ethanol, oils and other advanced renewable replacements for fossil fuel products.

Under the current regulatory structure, Comstock would directly produce and sell renewable fuels to qualify for federal incentives under the RFS. However, the EPA proposed modifications to the RFS in December 2021 to accommodate the growing potential of using biointermediates in the production of renewable fuels. Comstock’s February 2022 comments to the EPA supported and urged inclusion of the full range of America’s available woody biomass resources to produce biointermediates for sale to multiple downstream renewable fuel producers, thereby expediting the transition from petroleum to renewable fuels, and enabling the transformational changes envisioned by the Biden Administration to address the challenges of climate change. Comstock also urged the EPA to revise the renewable identification number (“RIN”) program to create ambitious additional categories for new and emerging technologies that can achieve 80%, 100%, and 120% greenhouse gas (“GHG”) reductions, as compared to the existing 60% cap on GHG reduction in the current RIN program, to fairly incentivize and accelerate transformational change.