Dear Clerk of the Board,
Attached please find the full comment of Pearson Fuels regarding
the Draft Scoping Plan.
The comment recognizes and appreciates the extensive work that
CARB staff has done on the Scoping Plan and supports its goals and
recommendations. The comment provides the following key
points and recommendations to facilitate the achievement of
California's GHG reduction goals.
· Pearson Fuels encourages CARB staff to
undertake the Low Carbon Fuel Standard carbon intensity rulemaking
with full dispatch.
Pearson Fuels provides the following
Ethanol and E85 uses are extremely effective GHG reduction
strategies that have delivered massive GHG reductions to
provides tremendous cost savings to consumers who own flex fuel
vehicles (FFVs) that can run gasoline or E85, currently in the
range of $1.50-$2.50 per gallon.
best available analysis has determined that to achieve carbon
neutrality, California must substitute bio-based gasoline for
fossil gasoline. E85 blended with renewable naphtha (E85/N15)
currently is the only commercially available bio-based
order to transition the legacy fleet from fossil gasoline to
bio-based gasoline in the form of E85/N15, CARB must establish new
programming to re-establish FFV manufacturing and better enable
certification of alternative fuel
Thank you for your
consideration of these comments. Please contact me if there
are any questions or problems with the filing.
Noyes Law Corporation
401 Spring Street, Suite 205
Nevada City, CA 95959