Submission Number: 31
Submission ID: 3666
Submission UUID: 3a6fd30f-9db9-4c9d-9643-9550282bc21b

Created: Tue, 06/06/2023 - 14:45
Completed: Tue, 06/06/2023 - 14:46
Changed: Wed, 06/07/2023 - 08:14

Remote IP address:
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes

Submitted Comment
Graham Noyes
Noyes Law Corporation for Low Carbon Fuel Producers
Proposal to Expand Use of Low Carbon Intensity Power

Dear Chair Randolph and Executive Officer Cliff,

Our diverse group of low carbon fuel producers and developers including Blue Arrow, Fulcrum BioEnergy, H Cycle, Infinium, Velocys, and World Energy (collectively, the “Low-CI Power Coalition”) appreciates the opportunity to offer comments on the Low Carbon Fuel Standard (“LCFS”) rulemaking.  As reflected in the attached Appendix 1, these leading-edge companies utilize a diverse range of low carbon feedstocks and advanced process technologies to produce the low carbon fuels of the future including electrofuels, hydrogen, renewable diesel and naphtha, and sustainable aviation fuel.    

These comments address the need for certain program refinements to enable the sourcing of low carbon intensity (“Low-CI”) power under the LCFS program.  These comments propose revisions to the LCFS program that would achieve additional GHG reductions by promoting the integration of new, additional clean energy resources.  Our proposed regulatory text is set forth in Appendix 2.  As low carbon fuel production continues to expand to decarbonize and defossilize California’s energy supply, the proposed LCFS program modification would create demand for new low carbon energy sources, rather than expanding fossil-based power demand.

Our full comment is attached.  We appreciate all of CARB's work to expand and improve the LCFS program, and to engage with stakeholders on these issues.

Best Regards,



Graham Noyes

Noyes Law Corporation

401 Spring Street, Suite 205

Nevada City, CA  95959 




(530)264-7157 Direct