Comment Log Display

Dear Clerk of the Board,

Attached please find the comments of H Cycle regarding the 15-day
proposed changes to the Low Carbon Fuel Standard.  A summary of the
comments is included here.  Please contact me if there are any
questions or issues relating to the filing.  Thank you for your
assistance.

H Cycle, LLC ("H Cycle") is pleased to submit comments pertaining
to the California Air Resources Board's ("CARB") proposed 15-day
changes ("15-Day Changes") to the Low Carbon Fuel Standard
("LCFS").  We support CARB's LCFS program as it sends a powerful
market signal to decarbonize the transportation sector, is
performance based, and provides long-term policy stability that
supports investment.  However, we respectfully encourage CARB not
to bias the LCFS program structure to favor more energy intensive
electrolytic hydrogen over H Cycle's non-electrolytic process that
leverages waste streams from organics diversion to reduce emissions
of the short-lived climate pollutant ("SLCP") methane, create a
distributed hydrogen production network, and attract federal
dollars to California to accelerate hydrogen production expansion. 


Best Regards,

Graham Noyes
Noyes Law Corporation for H Cycle
419 Broad Street, Suite E
Nevada City, CA  95959
www.fuelandcarbonlaw.com 
(530)264-7157 Direct
graham@noyeslawcorp.com