Laying the groundwork. Comstock Mining released comments submitted to the U.S. Environmental Protection Agency (EPA) proposing changes to renewable fuel standard rules 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 (RFS) program. Recall the company’s cellulosic fuels extraction and processing technologies are designed to convert woody biomass into renewable energy products, including carbon-neutral bio-intermediates and other precursors for renewable fuels.Proposed changes to RFS rules. Comstock proposes that the EPA: 1) expand definitions of biocrude, bio-intermediates, and renewable biomass to include bio-intermediates produced by thermal, chemical, and biological processes, 2) add qualifying feedstocks for use in generating renewable identification numbers (RINs), 3) remove limits on multi-facility bio-intermediate transfers, 4) add new RIN categories to promote greenhouse gas (GHG) reductions beyond the 60% cap in the current RIN structure, and 5) confirm the definition of “produced from renewable biomass” to include hydrogen sources from fossil fuels in producing bio-intermediates and renewable fuels.First-mover advantage. Comstock plans to produce bio-intermediates from woody biomass, by deploying increasing numbers of facilities per year, utilizing at least 50 million tons per year of suitable feedstock, with eventual capabilities to utilize over 85 million tons per year by 2030. Rating is Outperform. Comstock is making significant progress in advancing its plans for its new lines of business to promote decarbonization. This includes seeking changes to renewable fuel standard program rules to assure business alignment. If Comstock's proposals are adopted, we think it could validate and accelerate the company's plans for its Cellulosic Fuels business. Read More >>