Comment Log Display

Carbon TerraVault Holdings, LLC ("CTV") appreciates the opportunity
to comment on the California Air Resources Board's ("CARB" or "the
Board") proposed amendments to the Low Carbon Fuel Standard
("LCFS"), released on August 12, 2024 (the "15-Day Changes").

CTV believes that the proposed modifications to LCFS credit
generation for hydrogen projects is inconsistent with the
requirements of California's Administrative Procedure Act ("APA")
as well as CARB's December 2022 Scoping Plan (the "2022 Scoping
Plan"). CARB must not finalize the 15-Day Changes or CARB risks
suppressing California's nascent low-carbon hydrogen industry in a
manner that will inevitably increase the risk of stranding existing
assets and projects.

Restricting LCFS credits to non-fossil hydrogen after 2031:
- Does not align with CARB's 2022 Scoping Plan;
- Inhibits economic incentives that will constrict supply and the
California hydrogen sector;
- Ignores the State's technology-neutral approach to carbon
reduction; and
- Sends a message to investors that California's regulatory
agencies may arbitrarily change rules that negatively impact the
investment landscape without notice laid out by the state's own
legislation.

Please see the attached letter for details.