California Air Resources Board

The Methanol Institute appreciates the opportunity to offer these written comments on the California Air Resources Board (CARB) Proposed Amendments to the Low Carbon Fuel Standard (LCFS) regulations. I was one of the on-line Zoom attendees yesterday that did not get an opportunity to provide oral comments. During a discussion during the technical workshop in response to a comment regarding the use of methanol as a fuel for harbor craft, CARB staff noted that more data was needed on the use of methanol as a marine fuel, and we would he happy to engage with staff on this point.

The Methanol Institute believes the large-scale integration of low-carbon and net carbon-neutral fuels, such as renewable methanol, at an accelerated rate in marine applications, will be fundamental to achieving international targets for GHG reductions in the marine sector. Under the current LCFS regulations, renewable methanol is ineligible for credit generation because it is not identified as an opt-in fuel. Therefore, the Methanol Institute supports amending Section 95482 of the LCFS regulations to ensure that low-carbon intensity methanol is made eligible for LCFS crediting as an opt-in fuel when sold for use in marine vessels.