First Name: | Bernard Charles |
---|---|
Last Name: | Fenner |
Email Address: | bernard.fenner@ductor.com |
Affiliation | |
Subject | Ductor Americas Inc - LCFS comments |
Comment |
Dear Dr. Laskowski: Thank you for the opportunity to comment on the February 22, 2023 Public Workshop to Discuss Potential Changes to the Low Carbon Fuel Standard (LCFS). The LCFS is one of the most powerful climate change policies in the world, and it uniquely supports a wide array of innovative low carbon fuel production pathways. This can include pathways that significantly reduce emissions of N2O, such as projects that Ductor develops. We encourage you to strengthen the program through the amendment process to ensure it continues playing this unique role - delivering deep emission reductions from expected, and unexpected, sources. In particular, we offer the following recommendations: • Strengthen carbon intensity reduction requirements to align with levels needed to achieve outcomes in the 2022 Final Scoping Plan, including a target of at least 35% carbon intensity reduction by 2030. • Include a step-change in carbon intensity in 2024 to account for the current oversupply of credits and develop a one-way ratchet mechanism to provide certainty needed to develop new, low carbon fuel pathways, capture additional opportunities for carbon intensity reductions, and ensure the strength of the program on an ongoing basis. • Avoid changes to biogas pathway crediting that lead to high credit price spikes, including reducing book-and-claim opportunities for out-of-state biogas, which provides an important source of fuel and credits under the program. • Should CARB restrict book-and-claim of biogas, allow biogas to provide book-and-claim energy for all zero emission vehicle fuels equally (hydrogen production and electricity production) and as process energy to other fuel pathways. • Ensure that avoided N2O emissions are fully and completely valued in the program and calculators. • Update the Tier 1 calculator for dairy and swine manure to apply to all manure pathways, including biogas from poultry manure, and ensure accounting includes avoided N2O emissions and beneficial byproducts like organic and sustainable fertilizers. |
Attachment |
www.arb.ca.gov/lists/com-attach/85-lcfs-wkshp-feb23-ws-UzdXJFc1VnECa1Un.docx Original File Name: Ductor LCFS comments_2.22.23 Workshop final.docx
Date and Time Comment Was Submitted: 2023-03-15 14:39:16 |
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