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Comment #52 for Public Workshop to Discuss Potential Changes to the Low Carbon Fuel Standard
(lcfs-wkshp-jul22-ws) - 1st Workshop

First Name: Graham
Last Name: Noyes
Email Address: graham@noyeslawcorp.com
AffiliationNLC for FS Bioenergia
SubjectFS Bioenergia Comment RE: LCFS Rulemaking
Comment 
Dear Clerk of the
Board


Attached please find the comments of FS Bioenergia
(FS) regarding recommended changes to the LCFS regulatory structure
pertaining to the following issues:


*Recognition within CA-GREET of the benefits of
sequential cropping that substantially improves the yields and
economics of existing agricultural lands


*Establishment of default values within the Tier
1 calculator for crops produced under a system of sequential
cropping


*Recognition of purpose-grown woody biomass as
carbon neutral in a manner consistent with IPCC's treatment of this
material


FS'
complete comment is attached.   Please contact me if
there are any issues with the transmission, or for any discussions
relating to these comments.  FS appreciates the opportunity to
provide comments to CARB regarding the LCFS regulatory
program.


Best Regards,


Graham Noyes


Noyes Law Corporation for FS
Bioenergia


www.fuelandcarbonlaw.com 
Attachment www.arb.ca.gov/lists/com-attach/59-lcfs-wkshp-jul22-ws-BWZdNAZqWWdQM1U7.pdf

Original File Name: Comments on July 7th_FS_Discuss Potential Changes to the Low Carbon Fuel Standard.pdf

Date and Time Comment Was Submitted: 2022-08-08 13:26:50


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