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In response to the requirements of SB 617 and the California
Environmental Quality Act (CEQA), ARB is welcoming public input
on alternatives to the existing regulation and concepts in the
LCFS Re-Adoption Concept Paper released on March 7, 2014. State
rulemaking and environmental law supports public input in this
ongoing ARB process aimed toward a Low Carbon Fuel Standard
(LCFS) rulemaking proposal for Board consideration in fall 2014. 
As part of that process, ARB encourages public input on
alternative LCFS approaches:  specifically, any approach that may
yield the same or greater benefits than those associated with the
proposed regulation, or that may achieve the goals at lower
cost.

To submit an alternative for ARB to analyze in its Standardized
Regulatory Impact Analysis (SRIA) under SB 617 (see
http://www.dof.ca.gov/research/economic_research_unit/SB617_regulation/view.php)
and/or under CEQA, please ensure that your submission discusses
the alternative’s ability to fulfill the purposes of the draft
regulatory proposal as ARB has presented it.  To enable
comparison of economic impacts, please submit the quantities of
low-CI fuels used each year to comply with the alternative, as
well as the associated cost and benefit information, and their
sources.  Please also submit a clear description of the basis for
any cost calculations.

For environmental alternatives, please state the potentially
significant adverse environmental impact(s) your alternative is
seeking to address, and discuss how your proposed alternative
would avoid or substantially lessen that impact while meeting
most of the draft staff proposal’s basic purposes.

ARB will consider all alternatives provided in deciding which
alternatives will be carried forward for more detailed analysis
as part of the rulemaking process.

The deadline for submission of alternatives relating to economic
impacts is Friday, June 6, 2014.  Alternatives may be submitted
via email to Ms. Kirsten King, at kking@arb.ca.gov.

The Low Carbon Fuel Standard, a regulation to reduce the carbon
intensity of fuels sold in California ten percent by 2020, is one
of the measures adopted by the California Air Resources Board,
pursuant to Health and Safety Code Sections 38500-38599 (AB 32)
to reduce greenhouse gases in California.  It is designed to help
clean the air, protect the environment, and drive the development
of clean, low-carbon fuels.


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