Comment Log Display

I am writing to you to express support for the Novel Technology
Investment Credit (NTIC) program that was presented by Virent and
Marathon in the LCFS Public Workshop on Oct. 15, and offer my 
encouragement that CARB move the NTIC program into the next rule
making process for incorporation  into the LCFS.

As a former member of the corporate strategy group with Tesoro, I
have been following the LCFS program since its inception, and have
developed compliance strategies (including capital investment) from
the standpoint of an obligated party.  I continue to follow the
LCFS program closely, in my role as a member of the Board of
Directors of Ensyn Corporation, and as an advisor to California
Ethanol and Power.

I support the NTIC program because I believe it would be a good
structure to grow the supply of low carbon fuels for use in
California. It will help companies bring new technologies for low
carbon fuels to commercial scale by providing additional incentives
to encourage companies to take the economic risks to make large
investments to increase the production of these fuels.  In addition
to promoting the development of new technologies, this structure
could be equally valuable in providing incentives for more proven
technologies which have not yet been deployed commercially in
California due to other technical or financial challenges.  I
believe that the NTIC program would bring significant additional
investments into new low carbon fuels technologies and result in
significant increases in production of low carbon fuels.

For all these reasons, I encourage you to move the NTIC program
forward in the CARB rule making process.