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Dear Executive Officer Cliff,

The attached comment letter is submitted on behalf of my client
Raízen Energia S.A.  ("Raízen").  Raízen appreciates the
opportunity to provide comments on the Proposed 15-Day Changes to
the Low Carbon Fuel Standard (LCFS) Regulation.

We recognize and commend the efforts made by CARB to enhance the
clarity and precision of the regulatory language in response to the
Office of Administrative Law's (OAL) direction. The updated
language contained in the 15-Day Changes addresses the ambiguity
concerns raised by OAL, contributing to improved regulatory
transparency and compliance.

In particular, we welcome the explicit recognition and
incorporation of more regionalized tools, such as MapBiomas, in the
Land Use Change (LUC) section. This is a valuable step forward in
capturing land use dynamics with greater granularity and local
accuracy. 

Raizen's full comment is attached.

Best Regards,
Graham Noyes