Dear Clerk of the Board,
The Low Carbon Fuels Coalition (LCFC) appreciates the
opportunity to offer comments on the LCFS Workshop of July 7, 2022.
The LCFC is comprised of a diverse set of companies and
stakeholders dedicated to decarbonizing the transportation fuels
sector by developing and implementing the use of low carbon
fuels. The LCFC submits input regarding three issues of
importance to the rulemaking:
Increasing Stringency- Accelerating workshops and a rulemaking to update the LFCS
carbon intensity targets, both pre-2030 and post-2030 so that
targets align with California’s long-term climate goals,
should be a top priority for the Air Resources board in the
immediate future.
Proposed technology
sunset on forklifts- The LCFC encourages ARB to carefully consider any proposals
to sunset individual technologies, including the full implications
for private investments and possible unintended
consequences.
Proposed cap on
crop-based biofuels
The LCFC would also like to emphasize the importance of
developing the LCFS program based on established scientific
determinations, the best possible models, and regulatory outcomes.
This approach is properly designed to yield the most cost-effective
carbon intensity reductions for all modes of transportation, and
contrasts with designating fuel or feedstock categorization
approaches that pick winners and losers.
Our complete comments is attached. Please
contact me regarding any problems in transmission or any
discussions regarding the comment.
Best Regards,
Graham Noyes
Executive Director
Low Carbon Fuels Coalition
www.lcfcoalition.com