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I would like to bring a couple items to ARB attention.  

First is that as I project credit/deficit generation forward, ARB
will need to deal with credit generations in 2023, 2024, 2025, and
2026 that put the entirety of the program in jeopardy.  I show net
credit generation of ~1.5 million tons projected for 2022 (which is
manageable) but net credit generation of 7+ million per year for
the next 5 years with a peak net credit generation over 11 million
in 2025 and a cumulative credit bank approaching 60 million tons by
2028.  Carbon reduction based projects will fail and banks will
stop financing projects.  Innovation will stall.  It will be tough
to get beyond a 25% reduction much less hit net zero targets. 
There is also no scenario where a straight line regression can
solve this problem without forcing potentially damaging
ramifications in later years.  I would suggest ARB explore a
significant step down in 2023, 2024, and 2025 to address all the
new renewable diesel projects starting up during this period
followed by a flat line regression to 2030.  I would also suggest
you make this change before the 2023 Rulemaking process.

Second, I am disappointed that the program is now picking
technology winners and losers with its push for ZEVs. Don't get me
wrong, I understand the need for California to incentivize ZEVs
because of its geography and the health and safety benefits to
forcing any combustion, including combustion to generate electrical
power, outside of the state.  That said, the amount of innovation
the program spurred because it was technology agnostic was
astonishing to watch.  I fear you will lose some of this innovative
spirit by forcing a technology into the market.  

One of the program's core goals is to have a platform that is
expandable into other geographies.  Doing so with a forced
technology platform, especially one that requires the amount of
growth ZEVs require, is dangerous and shortsighted.  I would
appreciate if ARB would note that not all geographies have as clean
of electricity as California and some areas may have non-ZEVs that
are actually better for the environment than battery vehicles.

Lastly, I would urge you to consider fuels made from forest
management in this scoping plan.  CA forests have changed from a
carbon sink to a carbon emitter due to the drought and wildfires
caused by climate change.  Forest management practices can reduce
the probability for wildfire and resulting uncontrolled burn
emissions associated with them.  It can also save lives.  It won't
be perfect but it could help.

Thank you for your time and please feel free to reach out if you
have any questions about my comments above.