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Good afternoon.  My name is Ashley Remillard and I am Senior Vice
President of Legal and Government Affairs at Hexagon Agility. 
Hexagon Agility is the leading global provider of renewable natural
gas fuel systems for medium- and heavy-duty commercial vehicles.   

I want to address one aspect of staffs' comments relating to the
industry's request to prioritize the lowest certified engines. 
Staff stated that natural gas vehicles are not necessarily cleaner
than diesel trucks.  This ignores the benefits of renewable natural
gas.  Approximately 98% of natural gas used for transportation in
California comes from methane emitted by renewable sources,
including landfill waste, livestock manure, and wastewater
treatment plants.  As reported by CARB in 2022, renewable natural
gas in California is the only fuel with a negative carbon intensity
value.  This means that the fuel actually reduces the potential of
global warming in the atmosphere.  
We therefore strongly urge CARB to include language in the final
ACF regulation that prioritizes the purchase of the cleanest
available engine technology, running on renewable natural gas, when
an exemption is granted due to ZEV/NZEV unavailability.
Thank you.