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Comment 293 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameGraham
Last NameNoyes
AffiliationNoyes Law Corporation for Pearson Fuels
SubjectPearson Fuels Draft Scoping Plan Comment

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 input:

·      Ethanol and E85 uses are extremely effective GHG reduction strategies that have delivered massive GHG reductions to California.

·      E85 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.

·      The 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 gasoline.

·       In 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 retrofits.

Thank you for your consideration of these comments.  Please contact me if there are any questions or problems with the filing.

Best Regards,



Graham Noyes

Noyes Law Corporation

401 Spring Street, Suite 205

Nevada City, CA  95959 


(530)264-7157 Direct

@Graham Noyes


Original File NamePearson Fuels Scoping Plan Comments_24 June 2022_FINAL.pdf
Date and Time Comment Was Submitted 2022-06-24 14:41:02

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

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