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Dear California Air Resources Board:

Vopak is submitting this letter of support for the inclusion of
green methanol as a marine fuel into the Low Carbon Fuel Standard
(LCFS).

Vopak operates bulk liquid marine terminals in ports around the
world, including the ports of Los Angeles and Long Beach.  Vopak
does not own the products that we store, but we are a service
provider that helps products that are critical to our society,
safely and efficiently flow to end users.  In Los Angeles and Long
Beach, Vopak is a critical part of the infrastructure, handling
significant portions of the supply of jet fuel and Sustainable
Aviation Fuel (SAF) destined for Los Angeles International Airport
(LAX) and bunker fuels and renewable diesel used to fuel many of
the vessels calling on the ports.

The commercial aviation industry and the maritime shipping industry
are two industries that are not suitable for full electrification. 
The use of SAF for aviation and green methanol for maritime
activities can result in significant reductions in carbon emissions
over a relatively short timeline.  With regard to green methanol, a
major advantage of this fuel is the current existence of
infrastructure capable of handling this product in California
ports.  For example, storage tanks that store traditional marine
fuels today can be repurposed to handle green methanol.  Similarly,
barges that transport traditional bunker fuels to vessels within
the port today can also be repurposed to handle green methanol.

In contrast, other zero carbon or low carbon fuels being proposed
for the marine sector will require the construction of completely
new facilities and equipment that would take many years  to permit
and construct.  And, since those other fuels present significantly
higher risk profiles compared to traditional marine fuels or green
methanol, it will be extremely challenging for those projects to
obtain the California Environmental Quality Act (CEQA)
certifications necessary to move forward.

The use of green methanol will reduce both carbon emissions and
improve air quality.  Compared to conventional fuels such as
diesel, green methanol cuts carbon emissions by up to 95%, reduces
nitrogen oxide emissions by up to 80% and completely eliminates
sulfur oxide and particulate matter emissions.                     
                      (see https://www.methanol.org/renewable/)

Amending the LCFS regulations to allow low carbon intensity green
methanol to generate credits when used in marine transportation
will incentivize its use as a substitute for conventional fuels,
leading to an overall reduction of marine transportation related
emissions.

Making this change will help California realize its goals to
improve air quality and address global climate change.

Sincerely,



Vopak Terminal Los Angeles Inc.
Vopak Terminal Long Beach Inc.



Michael LaCavera
SVP Commercial & BD U.S. & Canada