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Hello, while I understand the goal of reducing emissions, the
draconian edict of "arbitrarily" saying you must be producing in
2023 to have the ability to "wait" until 2028 to adjust your supply
chain is illogical and very damaging to companies who have invested
near billions to provide California with renewable fuels.  Your
decision to allow those who were producing in 2023 the ability to
"wait" until January 2028 is a nod to common sense, but the
deadline of "you have to have been producing in 2023 to get this
accommodation is quite harmful to many not only producers of
renewable fuels but of their suppliers who have contracts to
furnish them with feedstocks.  The goal of CARB (end result at
least) is to incentivize foreign feedstocks, and punish North
American companies.

The 2023 stipulation is harmful and should be removed to allow
companies who did not produce in 2023 but are producing now, to be
able to adjust in a timely, not harmful manner.   Many plants were
constructed to supply California with better fuels, yet encountered
delays in being built during a very difficult supply chain
situation over the last 4-5 years.  I ask that you not punish them
for an arbitrary deadline and treat them the same as those who have
been producing in 2023 and prior it would be extremely harmful if
you kept the proposal, but hardly damaging to the goals of CARB.

Thank you,
Danny Tonasio