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Comment 13 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: Noyes Law Corporation

Subject: Comment by Fulcrum BioEnergy RE: Low-CI Power Sourcing for Facilities
Comment:
Attached please find the comment letter of my client, Fulcrum
BioEnergy, regarding low carbon intensity process energy (Low-CI
Power). This comment recommends that CARB authorize low carbon fuel
production facilities to acquire Low-CI Power via firm power
purchase agreement (PPA).  The current requirement of a direct
behind the meter connection is simply not feasible for many
facilities.  Allowing the sourcing of Low-CI Power via firm PPA
would increase the utilization of renewable energy and decrease
demand for fossil fuels, thereby facilitating California's policy
objectives.

The attached comment describes this recommendation in additional
detail.  Please contact me for any questions or to schedule a
meeting regarding this recommendation.  Thank you for the
opportunity to submit comments to this rulemaking.

Best Regards,

Graham Noyes
Noyes Law Corporation for Fulcrum BioEnergy 

Attachment: www.arb.ca.gov/lists/com-attach/14-lcfs-wkshp-oct20-ws-BmBQIwdqADAAdAB1.pdf

Original File Name: Fulcrum LCFS Comment RE Low CI Power.pdf

Date and Time Comment Was Submitted: 2020-11-02 10:45:00



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