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/