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Comment 12 for Low Carbon Fuel Standard Public Workshop to Discuss Potential Regulation Revisions (lcfs-wkshp-oct20-ws) - 1st Workshop.


First Name: Graham
Last Name: Noyes
Email Address: graham@noyeslawcorp.com
Affiliation: Attorney for SAF Producer Group

Subject: LCFS Recommendation from Sustainable Aviation Fuel Producer Group
Comment:
This comment is submitted on behalf of the Sustainable Aviation
Fuel Producer (SAF) Group which includes many of the leading
developers and producers of SAF including Fulcrum BioEnergy, Gevo,
LanzaJet, Red Rock Biofuels, Velocys, and World Energy. This
comment recommends that CARB revise the benchmarking table in the
regulation (Table 3) for Alternative Jet Fuel (AJF) in order to
comparably incentivize AJF and renewable diesel from a California
policy perspective.  The attached letter describes the requested
change in detail.  This policy modification is necessary to expand
supply of AJF to meet California's policy goals.

Thank you for the opportunity to submit this comment.  Please
contact me with any questions, or to schedule a meeting to discuss
this recommendation.

Best Regards,

Graham Noyes
Noyes Law Corporation
on behalf of the SAF Producer Group 

Attachment: www.arb.ca.gov/lists/com-attach/13-lcfs-wkshp-oct20-ws-B2lTOVQ2UV1QJQFg.pdf

Original File Name: NLC SAF LTR TO CARB LCFS 25 Sept 2020.pdf

Date and Time Comment Was Submitted: 2020-11-02 09:29:35



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