September 8, 2023 

RE: Support for the Summit Carbon Solutions Project (Docket #HP22-001) 

Members of South Dakota Public Utilities Commissions –
Gevo has been excited, up to this point, to call South Dakota home to our first large scale Sustainable Aviation Fuel (SAF) facility in Lake Preston. This plant is called Net-Zero 1 and we intend to produce 62 million gallons annually of renewable fuel (SAF, Renewable Diesel and Naphtha), hire 90 full-time employees, and employ up to 1,500 construction workers over the next three years. At more than $1 billion of fully installed and financed investment to build the SAF plant and $150 million for the wind turbine facility, the Lake Preston plant has been expected to be the largest investment South Dakota has ever seen. We have been excited to get building and hiring in the coming months and years to bring this project to completion.

Gevo’s mission is to transform renewable energy and carbon into energy-dense liquid hydrocarbons. These liquid hydrocarbons can be used for drop-in transportation fuels such as gasoline, jet fuel and diesel fuel, that when burned have potential to yield net-zero greenhouse gas emissions when measured across the full life cycle of the products. Gevo uses low-carbon South Dakota corn as raw materials and is in an advanced state of developing renewable electricity and renewable natural gas for use in production processes, resulting in low-carbon fuels with substantially reduced carbon intensity (the level of greenhouse gas emissions compared to standard petroleum fossil-based fuels across their life cycle).

To develop net-zero carbon SAF, Gevo is focused on capturing as much carbon reduction as possible through the entire ethanol to SAF production processes. This will begin with working directly with farmers to incentivize climate smart agricultural practices that reduce their carbon emissions. Carbon Capture and Sequestration (CCS) is an important part of reducing the carbon intensity of our fuels below net-zero. As Gevo builds the Net-Zero 1 plant, CCS opportunities are important to ensuring the long-term profitability and viability of the plant. Therefore, Gevo is working directly with Summit Carbon Solutions to connect to their pipeline network in South Dakota and Iowa to dramatically reduce our CO2 emissions from our production. This partnership is in-line with our net-zero mentality and is essential for Gevo to achieve beyond zero carbon emissions. 

We believe carbon capture and sequestration is going to be a competitive standard in SAF production given the potential economic impact and measurable reduction of the carbon footprint; and that so many states are supportive of CCS. If a CCS pipeline is not available to the Lake Preston Net-Zero 1 plant, this facility will be economically 2 disadvantaged to other locations we are actively working to develop across the country. Failure for the Summit pipeline to be built in South Dakota puts our Lake Preston project in severe risk of being relocated to a more advantageous location that has the availability of CCS.

Gevo supports the establishment of the Summit Carbon Solutions pipeline due to its direct benefit to our enterprise, but also for the ability to significantly reduce the carbon emissions from ethanol plants across the state. In the global fight to maintain ethanol production and corn basis, innovative ideas like carbon sequestration pipelines are an important step to limiting the carbon intensity of renewable fuels in the transportation sector. 

CCS pipelines are recognized as an important part of market-based climate policy. Low carbon fuel standards include CCS as an option for decarbonizing renewable fuel production. CCS is an effective and important tool for a low carbon future and these markets are what spurs the Midwest effort to decarbonize ethanol and SAF production. Additionally, the Federal 45Q program was expanded just a year ago to encourage the growth of CCS. These state and federal policies demonstrate the urgent need to support CCS and the nationwide support it has to decarbonize renewable fuel production. 

Gevo has a history of working with South Dakota based companies, universities, and corn growers to develop environmentally friendly products. This is a testament to South Dakota as such a great state to do business. As we look for future sites for additional plants, South Dakota remains high on our list. Proximity to a CCS pipeline is a major consideration Gevo has as we make decisions on new Net-Zero SAF locations. 

The permitting of any major project is challenging and Gevo appreciates the robust conversation taking place to discuss this pipeline and all efforts to reduce carbon. Gevo supports Summit Carbon Solution’s application, and we encourage the Public Utilities Commission to approve it. This is an important moment for renewable fuels, carbon reduction, agriculture, and future economic development that will enhance environmentally friendly products in the state.


Respectfully,
Kent Hartwig
Director of State Government Affairs