Comment Log Display

On behalf of more than three dozen cross-sectoral organizations, we
respectfully submit the attached critical process and substantive
recommendations for CARB to fix the LCFS. We urge CARB to provide a
non-voting, informational Board hearing, which will allow for more
time and the opportunity for meaningful public and Board
engagement. This need for more engagement opportunities is
underscored by the major deficiencies that remain in the current
proposal. We urge CARB to prioritize fixing the LCFS this year in
the following ways: 
  A. Reign in bogus credits that are depressing the credit price,
distorting markets, and harming people and ecosystems by:
        - Eliminating avoided methane crediting for fuel derived
from livestock manure. 
        - Capping the use of lipid biofuels. 
  B. Leverage the LCFS to achieve a zero-emissions future for all
Californians by:
        - Creating ZEV multipliers to boost electric school bus and
electric public transit bus and rail system deployments. 
        - Following through with the inclusion of intrastate jet
fuel as a deficit generator and starting to analyze the path toward
including California's share of the fuel used in interstate and
international flights. 
        - Allowing credits for zero-emission transportation fuels
used for ocean-going vessels, and simplifying the process for
credits for shore power installations serving electrified harbor
crafts and for dispensing green hydrogen.