These attached comments are submitted by the
International Council on Clean Transportation (ICCT). The ICCT is
an independent nonprofit organization founded to provide unbiased
research and technical analysis to environmental regulators. Our
mission is to improve the environmental performance and energy
efficiency of road, marine, and air transportation, in order to
benefit public health and mitigate climate change. We promote best
practices and comprehensive solutions to increase vehicle
efficiency, increase the sustainability of alternative fuels,
reduce pollution from the in-use fleet, and curtail emissions of
local air pollutants and greenhouse gases (GHG) from international
goods movement.
The ICCT welcomes the opportunity to provide comments
on the Air Resources Board’s July meeting to discuss
potential changes to the Low-Carbon Fuel Standard. We commend the
agency for its dedication to assessing its progress towards its
climate goals and its willingness to evaluate policy options to
meet its targets. The attached comments below offer a number of
technical observations and recommendations for ARB to consider as
it reviews the contributions of the Low-Carbon Fuel Standard (LCFS)
to its broader climate goals.