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Comment #2 for Public Workshop to Discuss Potential Changes to the Low Carbon Fuel Standard
(lcfs-wkshp-jul22-ws) - 1st Workshop

First Name: Nate
Last Name: Underwood
Email Address: nate@fleetzero.com
Affiliation
SubjectExpand LCFS to Containerized Ocean and Inland Waterway Shipping Immediately
Comment

Dear CARB,

Thank you for your work to date on the Low Carbon Fuel Standard (LCFS) and for considering expansion into the maritime domain. 

My company Fleetzero (https://www.fleetzero.com/) is going to market with battery electric ocean cargo shipping. It is our understanding that we can generate LCFS credits from charging our swappable battery energy storage systems on land, but LCFS does not currently cover ocean or inland waterway shipping of any kind. 

Given battery cost reductions that are enabling the cost-effective transition to battery electric containerized shipping, we request that the LCFS immediately (as soon as the regulatory process allows) expands to cover all ocean and inland shipping. Since greenhouse gas emissions are a global pollutant, this update to LCFS should cover all emissions for containers delivered to California ports. This should include anti-leakage measures to cover attempts to tranship containers to dodge regulations (ex. shippers switch trips from China to Long Beach and instead ship China, Portland, Long Beach). If current laws authorizing LCFS do not allow covering global emissions of containers delivered to California ports, the covered geographic region should be as large as possible, but at a minimum covering California territorial waters and emissions generated in other states. 

LCFS expansion to maritime transportation should also cover embedded energy of production and potential leakages during transportation and use phases from fuels such as natural gas and hydrogen. 

LCFS revenue should support upfront subsidies to cover the high costs of U.S. shipbuilding, charging infrastructure, and swappable battery energy storage systems (along with competing zero emissions sustainable energy sources). 

Additionally, all LCFS revenue and California programs should enable any type of ship to participate. One current issue is that some CARB programs have rules written for specific types of ships (harborcraft, ferries, etc.) and this excessive clarity can exclude freight ship types like container ships, tugs, and barges. 

Thank you for all of your work on advancing emissions reductions in California, and please reach out if you have any questions. 

Regards,

Nate

Head of Growth

Fleetzero

https://www.fleetzero.com/

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Date and Time Comment Was Submitted: 2022-07-21 16:50:08


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