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Comment 207 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameNikita
Last NamePavlenko
SubjectICCT Comments on AB32 Scoping Plan and Changes to the LCFS Program

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 ( and Dr. Stephanie Searle (

Original File NameCA AB32 Scoping Plan Comments_0.4_Clean.pdf
Date and Time Comment Was Submitted 2022-06-24 10:06:55

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.

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