Comment Log Display

Dear Clerk of the Board,

The following is a summary of this comment.  Attached please find
the full comment submitted on behalf of Aether Fuels, Air Company,
Airlines for America, Arcadia, Dimensional Energy, Infinium, TES,
and Twelve.

The signatories of this letter are pleased to submit comments
regarding the modifications ("15-Day Changes") that the California
Air Resources Board ("CARB") has made to its previously proposed
amendments to the Low Carbon Fuel Standard ("LCFS").  The specific
changes that we are commenting upon are the changes made to
proposed §95488.8(i)(1) pertaining to "Book-and-Claim Accounting
for Low-CI Electricity Supplied as a Transportation Fuel, Direct
Air Capture projects, or Used to Produce Hydrogen as a
transportation fuel."  These 15-Day Changes modify the fuels that
are eligible to use Book-and-Claim Accounting and modify the
requirements for Book-and-Claim Accounting.  We disagree with these
modifications because the proposed LCFS regulations do not
authorize Power-to-Liquid ("PtL") fuels to use Book-and-Claim
Accounting despite the vital importance of PtL fuels to
transportation decarbonization.  This comment is submitted
consistent with the requirements of Government Code §11346.8(c).

Please let me know if there are any questions relating to this
comment or filing.

Best Regards,

Graham Noyes
Noyes Law Corporation
419 Broad Street, Suite E
Nevada City, CA  95959
www.fuelandcarbonlaw.com 
(530)264-7157 Direct
graham@noyeslawcorp.com 
https://www.linkedin.com/in/grahamnoyes
@Graham Noyes