| Comment | We appreciate CARBs overall approach of world-class standards
complimented by incentives and price signals for the transportation
sector. Specific to cap & trade, we recommend replacing the
biofuels
exemption with accounting that can track the LCFS. We support your
proposal to auction the GHG allowances for transportation tailpipe
emissions in 2015. In the meanwhile we recommend reducing the
amount
of free allowances for upstream petroleum reduction, which would
allow
for the potential use to support transition to cleaner and more
efficient forms of transportation. Thank you for your consideration
of
our comments.
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