The attached file includes comments submitted by the
International Council on Clean Transportation (ICCT). The ICCT is
an independent nonprofit organization founded to provide unbiased
research and technical analysis to environmental regulators. Our
mission is to improve the environmental performance and energy
efficiency of road, marine, and air transportation, in order to
benefit public health and mitigate climate change. We promote best
practices and comprehensive solutions to increase vehicle
efficiency, increase the sustainability of alternative fuels,
reduce pollution from the in-use fleet, and curtail emissions of
local air pollutants and greenhouse gases (GHG) from international
goods movement.
The ICCT welcomes the
opportunity to provide comments on the Air Resources Board’s
May AB 32 Climate Change Scoping Plan. We commend the agency for
its dedication to assessing its progress towards its climate goals
and its willingness to evaluate policy options to meet its targets.
The comments below offer a number of technical observations and
recommendations for ARB to consider as it reviews the contributions
of the Low-Carbon Fuel Standard (LCFS) to its broader climate
goals.
We would be glad to
clarify or elaborate on any points made in the below comments. If
there are any questions, ARB staff can feel free to contact Nik
Pavlenko (n.pavlenko@theicct.org) and
Dr. Stephanie Searle (stephanie@theicct.org).
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