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I comment representing The Transport Project, a national collective
of fleets, vehicle and engine manufacturers, servicers and
suppliers, and fuel producers and providers dedicated to the
decarbonization of North America's transportation sector.

Through the increased use of gaseous motor fuels including
renewable natural gas and hydrogen, we can achieve ambitious
climate goals and greatly improve air quality safely, reliably, and
effectively without delay and without compromising existing
commercial business operations.

Our roughly 200 member companies and fleets support the proposed
modifications before you and encourage their adoption.  They are
not perfect, nor ideal for all, including our members, but they
represent a rational, comprehensive, and consistent approach to
strengthening the LCFS program and continuing its emissions
reduction success.

Moving forward, it is important that CARB advance an LCFS that:
•	Focuses on vehicles and fuels used;
•	Centers on their well-to-wheel emissions, providing a level
playing field for all; and
•	Creates investment certainty by continuing to reward
agriculturally based reductions including those achieved by the
production of biofuels, especially RNG and Hydrogen produced from
RNG.

Thank you for considering our position.