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The attached comments are submitted by the International Council on
Clean Transportation (ICCT). The ICCT is an independent nonprofit
organization founded to provide unbiased research and technical
analysis to environmental regulators. Our mission is to improve the
environmental performance and energy efficiency of road, marine,
and air transportation, in order to benefit public health and
mitigate climate change. We promote best practices and
comprehensive solutions to increase vehicle efficiency, increase
the sustainability of alternative fuels, reduce pollution from the
in-use fleet, and curtail emissions of local air pollutants and
greenhouse gases (GHG) from international goods movement.


The ICCT welcomes the opportunity to provide comments on the Air
Resources Board's February LCFS workshop to discuss potential
changes to the Low-Carbon Fuel Standard. We commend the agency for
its technical analysis and interest in continuing to improve the
effectiveness of one of its flagship climate programs. Based on the
content of the workshop, the comments below offer a number of
technical observations and recommendations for ARB to consider in
future changes to the Low-Carbon Fuel Standard. 

Original File Name: Feb23 LCFS Workshop Comments_Clean_0.2_NP.pdf

Date and Time Comment Was Submitted: 2023-03-15 14:36:00