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The attached comment letter is submitted on behalf of the
sustainable aviation fuel (SAF) producer group. The SAF Producer
Group is composed of some of the world's leading companies
producing SAF or developing SAF production facilities including
Alder Fuels, Fulcrum BioEnergy, Gevo, LanzaJet, Red Rock Biofuels,
Velocys, and World Energy. Many of these companies participated in
the last major Low Carbon Fuel Standard (LCFS) rulemaking and
supported the inclusion of alternative jet fuel (AJF)1 in the LCFS
on an opt-in basis. The SAF Producer Group would like to commend
the California Air Resources Board (CARB) for CARB's decision in
that rulemaking to integrate AJF uplifted in California into the
LCFS effective January 1, 2018. CARB's policy leadership regarding
SAF has firmly established California as the leading SAF state in
the country from both a supply and demand standpoint and has placed
California in the top tier of locations globally supporting the
expansion of SAF.

We appreciate the opportunity to provide comments to the 2022
Scoping Plan pertaining to the aviation sector and of major import
to the SAF industry.

If there are any issues with the filing of this comment, or if
further information is requested, please contact me.

Best Regards,

Graham

Graham Noyes
Noyes Law Corporation
401 Spring Street, Suite 205
Nevada City, CA  95959
www.fuelandcarbonlaw.com 
(530)264-7157 Direct
graham@noyeslawcorp.com 
https://www.linkedin.com/in/grahamnoyes
@Graham Noyes