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Dear Ms. Singh:

I am an executive of Sirona Fuels, a biodiesel producer in the San
Francisco Bay Area. I write today to comment on the draft LCFS
regulation as discussed at the January 30, 2009 workshop and to
encourage an accelerated timeline for Biodiesel and other diesel
alternatives. 

I appreciate the change made in the implementation timeline from
the December workshop to begin implementation in 2011 but request
more be done.  According to the California Energy Commission,
California is using 43+million gallons of Biodiesel per year. 
California has nine Biodiesel plants operating, with an estimated
total production capacity of 63 million gallons per year; another 4
plants are idle and at least one is under construction.  The
existing infrastructure is more than capable of meeting the demands
of a one percent reduction in carbon intensity beginning January
2010.  Furthermore, according to the California Energy Commission,
the current AB 118 investment plan will allocate funding towards
the development of biodiesel blending and distribution
infrastructure.  I strongly recommend ARB to revise the
implementation timeline for the diesel fuel pool to include more
aggressive decreases in carbon beginning in 2010.

Thank you for your consideration of these comments.  Should you
have any questions or need additional information please call me at
415-244-4046.  

Sincerely,

Robert Kirsten