Submission Number: 844
Submission ID: 11316
Submission UUID: b756fb36-e18a-41ea-b0d3-392413e6c89c

Created: Fri, 05/10/2024 - 14:03
Completed: Fri, 05/10/2024 - 14:04
Changed: Mon, 05/13/2024 - 09:03

Remote IP address: 38.34.109.43
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes
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Submitted Comment
Nikita Pavlenko
ICCT
ICCT Comments on the April LCFS Workshop

The attached 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 Proposed Low Carbon Fuel Standard amendments. We commend the agency for its continued engagement and interest in continuing to improve the effectiveness of one of its flagship climate programs. The comments below offer a number of technical observations and recommendations for ARB to consider in aligning the program with the goals of the 2022 Scoping Plan. New analysis is based on the content presented in the April 10th workshop including modifications to the California Transportation Supply (CATS) model. We would be glad to clarify or elaborate on any points made in the attached comments.