As I was reading through the staff report, I came across certain provisions of pg.s X-9 & X-10 in re the 
Use of External GHG credits.  Now, according to the aforementioned paragraph, the use of GHG credits 
generated outside the LCFS Program is positively disallowed.  Such decision needs to be reconsidered.  
GHG reductions to be realized in marine, aviation, & rail transportation fuel improvements are specifically 
excluded from LCFS, but not from Federal legislation & regulation, necessarily.  Given the overall 
policy direction at the Federal level, as regards GHG reductions, etc., it would behoove CARB to 
reconsider the proposed exclusions, or else improvements to be realized cannot be considered in any 
GHG reduction tallies.  And for what cause?  In conclusion, the proposed exclusion of externally generated 
GHG credits (i.e., marine, aviation, & rail related) must be reconsidered for the purpose of removal from the 
proposed regulation.  Thank you.