Comment Log Display

On behalf of Clean Energy Fuels Corp., I officially submit our
final comments on the final draft proposal of the Low Carbon Fuel
Standard.  Clean Energy strongly supports this proposed regulation
and asks for four friendly amendments that will help our company
support the California Air Resources Board's and the State of
California's LFCS 2020 goals and beyond.  These four amendments in
summary are: (1) include "LNG from domestic sources" in the
"opt-in" list under Section 95480; (2) create two EER values for
spark-ignited and compression-ignition engines or blend the EER
values based on the engine data to a value of 0.95; (3) expand the
sale of LCFS carbon credits generated to the larger AB 32 cap and
trade program to non-regulated entities and require "regulated
parties" to purchase all available LCFS credits on the market
before allowing that entity to carry over its shortfall of 10% or
less; and, (4) revise the "biogas" definition to include Municipal
Solid Waste as a feedstock.  Thank you.