Comment Log Display

We believe that the program ARB is developing is a terrific one and
it will assist in the development of facilities that produce low
carbon fuels.  We appreciate the opportunity to submit our
comments/suggestions.

May we suggest that staff considers these two idea's:
1. Allow facilities that are in development to apply and qualify
for the producers payment.  While funds can't be released until the
facility is producing low carbon fuel, the debt and equity markets
will take into account this guaranteed revenue stream which will
assist the developers of these facilities during the financing
stage of their project.  

In addition, we strongly suggest that ARB awards the contracted
payments to a facility for as many years as possible so that the
financing entities can calculate the revenue into the financing
models for the project.  This will have a positive effect for
project financing until ARB can develop and implement a floor price
program.

2. We understand the chart developed by ARB for the potential per
gallon payments for each gallon produced.  We believe that the
scale is pretty steep, especially when projects with a relatively
low CI are just outside of the next level.  The difference of just
a couple of points could mean the difference of millions of
dollars.  We would like to suggest a more gradual scale.

Thank you again for allowing us to comment.