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Comment 5 for Low Carbon Fuel Standard - Policy and Regulatory Development (lcfs-policy-ws) - 1st Workshop.
First Name: Remy
Last Name: Garderet
Email Address: remy.garderet@einow.org
Affiliation: Energy Independence Now
Subject: LCFS comments on non-biofuel
Comment:
Dear Mr. Simeroth and Mr. Courtis, Attached please find comments submitted by Energy Independence Now on the LCFS. Our comments, in summary, cover the following points: 1. The LCFS appears well designed to incentivize low-level blending of biofuels into conventional fuels, and spurring innovation to source and create lower carbon varieties of these blends. (We offer some thoughts for its fine tuning in that regard). 2. However, although the scope of the LCFS extends beyond biofuels, we are deeply concerned that the LCFS mechanism will not provide a sufficient incentive for the development of these other ultra-low carbon technologies. This could impair our ability to meet long term GHG goals, and effectively leaves all our eggs in one basket - biofuels. 3. We therefore urge ARB to assign dedicated resources and a stakeholder process to address the particular needs of non-biofuel technologies, with special attention to electricity and hydrogen given their low carbon promise. Our letter provides suggestions on some of the key issues to address as part of this. Thank you for continued work in developing this innovative standard. Sincerely, Daniel Emmett Remy Garderet Energy Independence Now
Attachment: www.arb.ca.gov/lists/lcfs-policy-ws/6-ein_submission_on_lcfs.pdf
Original File Name: EIN Submission on LCFS.pdf
Date and Time Comment Was Submitted: 2008-02-12 12:06:30
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