Comment Log Display

These comments are submitted by the International Council on Clean
Transportation (ICCT). The ICCT is an independent nonprofit
organization founded to provide unbiased research and technical
analysis to environmental regulators. Our mission is to improve the
environmental performance and energy efficiency of road, marine,
and air transportation, in order to benefit public health and
mitigate climate change. We promote best practices and
comprehensive solutions to increase vehicle efficiency, increase
the sustainability of alternative fuels, reduce pollution from the
in-use fleet, and curtail emissions of local air pollutants and
greenhouse gases (GHG) from international goods movement.

The ICCT welcomes the opportunity to provide comments on the Air
Resources Board's proposed 15-day changes to the Low Carbon Fuel
Standard amendments. We commend the agency for its technical
analysis and interest in continuing to improve the effectiveness of
one of its flagship climate programs. The comments below offer a
number of technical observations and recommendations for ARB to
consider in aligning the program with the goals of the 2022 Scoping
Plan, restoring stable credit prices, and maintaining the
environmental integrity of the program.