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Comment 1 for Low Carbon Fuel Standard Program Review Advisory Panel (lcfspanel2014-ws) - 1st Workshop.


First Name: Alex
Last Name: Menotti
Email Address: amenotti@airlines.org
Affiliation: Airlines for America

Subject: LCFS Advisory Panel Public Comment Question-Inclusion of Jet Fuel and Low CI Renewable Die
Comment:
A4A writes to request that the LCFS Advisory Panel consider the
inclusion of sustainable alternative jet fuel as an eligible
credit-generating fuel as part of its review of the LCFS program,
even though it would not be subject to the LCFS mandate, consistent
with EPA’s approach under the Renewable Fuel Standard. As further
detailed in the attached letter that A4A submitted to CARB in July
2014, which we ask be included in the record for today’s meeting,
the omission of alternative jet fuel as an eligible
credit-generating fuel is a substantial disincentive to the
production of alternative jet fuel in the California market and
beyond.    

With regard to the panel’s discussion of fuel availability, much of
the volume of renewable diesel that CARB anticipates will be
available for LCFS compliance has already been contractually
committed to the production of renewable jet fuel. This includes
production from AltAir fuels and recently announced production at
Fulcrum Bioenergy and Red Rock Biofuels under the Defense
Production Act. CARB should not distort the market for alternative
fuels by seeking to attract LCFS-eligible renewable diesel from
these facilities for LCFS compliance. Instead, CARB should allow
for credit generation from either renewable diesel or jet fuel and
allow market participants to determine where the fuel is ultimately
allocated. Such an approach would lend more certainty to CARB’s low
CI fuel availability projections and eliminate concerns that the
LCFS may inhibit alternative jet fuel production.   

Numerous stakeholders have urged CARB to allow for alternative jet
fuel to generate credits under the LCFS in order to increase
compliance flexibility and eliminate distortions in the alternative
fuels market. CARB stated in the Final Statement of Reasons of the
2009 regulation that it would revisit the issue in the 2011
Advisory Panel review process. Unfortunately, the issue was not
addressed in the 2011 report.  We strongly urge the Advisory Panel
to address the issue in the current review and recommend the
adoption of amendments that would allow for alternative jet fuel to
generate credits under the LCFS.  

Sincerely, 



Alex Menotti 
Environmental Affairs Regulatory Manager
Airlines for America®
We Connect the World 
1301 Pennsylvania Ave, NW, Suite 1100
Washington, DC 20004
Phone: (202) 626-4151
Fax: (202) 626-4139
email: amenotti@airlines.org


Attachment: www.arb.ca.gov/lists/com-attach/2-lcfspanel2014-ws-WzpSYABgBAgEbgls.pdf

Original File Name: A4A letter to CARB re jet fuel and LCFS 7 15 14.pdf

Date and Time Comment Was Submitted: 2014-10-06 11:36:42



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