- I have submitted comments on both the ACC II regulation and
the 2022 Draft Climate Change Scoping Plan.
- In my submitted comments, I request that CARB staff prepare an
alternative analysis to the ACC II regulation. That alternative
calls for replacing the parts of the ACC II that require a waiver
from the U.S EPA with a statewide renewable liquid fuel standard of
25% content renewable fuel by 2030 and 50% by 2040.
- My request for an alternative analysis is made under CEQA,
which requires CARB staff to analyze environmentially superior
alternatives, and prepare a comparative analysis of the proposed
alternative to the proposed projects in the regulation.
- When CARB submits a waiver request to U.S EPA, CARB must show
it did not act in an arbitrary or capricious manner. Failing to
prepare an analysis of an alternative to a project that requires an
EPA waiver is arbitrary and capricious.
Thank you
Tom Becker
Buellton, CA